DEPUTY COMMISSIONER OF INCOME TAX, SALEM vs. GOVINDA RAJULU SRINIVASAN, SALEM

ITA 1245/CHNY/2025Status: DisposedITAT Chennai04 September 2025AY 2014-15Bench: SHRI ABY T. VARKEY (Judicial Member), SHRI AMITABH SHUKLA (Accountant Member)1 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the AO cannot make additions or disallowances on issues not mentioned in the reasons recorded for reopening the assessment. The Ld. CIT(A) was correct in quashing the reassessment order.

What were the facts?

The Assessing Officer (AO) reopened the assessment based on information regarding the sale of immovable property and TDS transactions. However, the AO made disallowances on entirely different grounds than those stated in the reasons for reopening.

What were the issues?

Whether the AO can make additions/disallowances on issues not forming the basis of the reasons recorded for reopening the assessment under Section 147.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 40A(3)

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Cases cited in this judgment(8)Show list

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Income Tax Appellate Tribunal, ‘C’ BENCH: CHENNAI

Before: SHRI ABY T. VARKEY & SHRI AMITABH SHUKLA

Hearing: 16.07.2025Pronounced: 04.09.2025

PER ABY T. VARKEY, JM: This is an appeal preferred by the Revenue against the order of the Learned Commissioner of Income Tax (Appeals)/NFAC, (hereinafter

referred to as ‘Ld.CIT(A)‘), Delhi, dated 13.02.2025 for the Assessment

Year (hereinafter referred to as ‘AY‘) 2014-15. 2. The main grievance of the Revenue is against the impugned action

of the Ld.CIT(A) allowing the legal issue raised by the assessee against

the reopening of assessment by the AO. Govinda Rajulu Srinivasan 3. Brief facts rel

The order continues below.

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