Section 147 Reassessment Unsustainable Due to Mismatch in Grounds & Disallowance

Balithal Gram Seva Sahakari Samiti Limited Vs ITO (ITAT Jaipur) Jaipur, May 21, 2025 – The Income Tax Appellate Tribunal (ITAT), Jaipur Benches, has allowed an appeal filed by Balithal Gram Seva Sahakari Samiti Limited, quashing the reassessment order passed by the National Faceless Assessment Centre (NFAC), Delhi, for the relevant assessment year. The Tribunal ruled that the reassessment proceedings initiated under Section 147 of the Income Tax Act, 1961, were not legally sustainable due to a fundamental mismatch between the grounds for reopening the assessment and the final disallowance ma...