Section 151A Breach: ITAT Quashes Reopening, ₹58.68 Cr Bogus Purchase Addition Deleted

JCIT Vs Sharmanji Yarns Pvt. Ltd. (ITAT Chandigarh)

Reopening Quashed: ITAT Holds Notice Invalid for Violation of Sec.151A & Wrong Sanction—58.68 Cr Bogus Purchase Addition Collapses

These cross-appeals arose from reassessment proceedings where the AO made a massive addition of Rs. 58.68 crore treating purchases from eight parties as bogus. CIT(A) restricted the addition to 9% estimation, resulting in appeals by both Revenue & Assessee.

At the threshold, Assessee raised two pure legal grounds:

 (1) Notice u/s 148 issued by wrong authority

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