2014 (7) TMI 1035 - ITAT AGRA - Income Tax
Assessment u/s 153A – Unexplained expenses – Held that:- The AO has challenged the order of the CIT(A) only on the jurisdictional issues whereas the relief is granted by the CIT(A) on merits as well - the scope of reassessment is only with regard to the income escaping assessment and the matter which have attained finality in original assessment cannot be re-agitated in reassessment proceeding - Relying upon ACIT Vs KS Food Products [2014 (7) TMI 897 - ITAT AGRA] - the scheme of Section 153 A does not permit such an exercise by the AO – revenue has not been able to point out our attention to any judicial precedent to support his case or demonstrate as to how the addition in respect of those very issues, which have received finality earlier and in respect of which no new or incriminating material is found, can be taken upon the course of proceedings u/s 153A on the basis of the search – the order of the CIT(A) is upheld – Decided against Revenue.
Regards
Prarthana Jalan
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