Share capital accepted in scrutiny assessment cannot be added in Assessment U/s. 153A

ACIT Vs SMC Power Generation Ltd. (ITAT Delhi)

ITAT held that assessment was earlier completed u/s 143(3) wherein the share capital had been scrutinized and accepted by the revenue, holding the same share capital as unexplained in the present reassessment u/s 153A tantamounts to change of opinion not backed by any evidence and, therefore, not legally sustainable.

FULL TEXT OF THE ITAT JUDGEMENT

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