Section 147 ‘Fishing Net’ Doctrine Upheld: ITAT Voids Reopening for Unrelated Additions

Shueb Urf Mohd. Kunwer Shueb Vs ITO (ITAT Delhi)

147 Is Not a Fishing Net – If You Don’t Catch the Fish, You Can’t Keep the Boat- No Addition on Issue of Reopening? Whole Assessment Goes in Trash

In this case, the reassessment was initiated u/s 148/147 solely on the ground that Assessee had allegedly made cash deposits of ₹26,06,500, & therefore income had escaped assessment. However, during the reassessment, AO did NOT make any addition whatsoever on this “reason recorded” issue. Instead, he went on to make other add

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