Reopening on Wrong Reason Quashed: ITAT Deletes Section 68 Addition

Passion Realtech Pvt. Ltd. Vs ACIT (ITAT Delhi) Reason Recorded ≠ Addition Made: ‘Fundamental Jurisdictional Infirmity’ – Reopening on Wrong Reason is Void: ITAT Delhi Quashes 147 & Deletes Full 68 Additions for Both Years- Loan Repaid, Identity & Genuineness Proved—Section 68 Additions Deleted Assessee, a real-estate company, was subjected to reassessment u/s 147 r.w.s 144 for both AYs. For AY 2011-12, AO recorded reasons alleging unexplained purchase of immovable property of Rs.2.98 crore, but completed reassessment by making addition of Rs.47 crore u/s 68, treating lo...