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 additions relating to Section 54F deduction, cost of acquisition...