2012 (3) TMI 471 - AT - Income Tax

Summary

Issues involved:
The judgment involves the appeal by the Revenue against the order of CIT(A), Panchkula dated 31.1.2011 relating to assessment year 2001-02 under section 143(3) of the I.T. Act, 1961.

Reopening of Assessment (Ground No. 1):
The Revenue challenged the quashing of the assessment reopened under section 147, contending that the reasons recorded by the AO lacked basis. The CIT(A) held that the reasons for reopening did not have a rational connection to the formation of belief of income escapement, citing the Supreme Court's decision in ITO v. Lakhmani Mewal Das. The Tribunal upheld the CIT(A)'s decision, stating that the re-assessment proceedings were without basis and bad in law.

Additions Made by AO (Ground Nos. 2-5):
The Revenue contested the deletion of various additions made by the AO, including an addition for an alleged FD, expenses on a ring ceremony, unexplained jewelry, and expenditure on clothes. The CIT(A) examined each addition and found in favor of the assessee, citing evidence provided and financial capacities. The Tribunal upheld the CIT(A)'s decisions on each item, dismissing the Revenue's grounds.

General Grounds (Ground Nos. 6-7):
The general grounds raised by the Revenue were dismissed by the Tribunal.

In conclusion, the appeal filed by the Revenue was dismissed by the Tribunal on March 29, 2012.