2012 (11) TMI 895

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..... of which additions were made were not found valid or justifiable as those additions were deleted by the Tribunal. Since the grounds for reopening the reassessment do not exist any longer and no additions were ultimately made on that account, the additions in respect of other items which were not part of "reasons to believe" cannot be made. - Decided in favor of assessee. - ITA No. 2090 of 201 .....

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..... he return, pursuant to said notices, declaring the same income as was originally written. The AO passed the reassessment order dt. 23rd Dec., 2006 making additions of Rs. 31 lacs on account of unexplained share capital including the capital subscribed by the aforesaid three applicants on the basis of which the assessment was reopened by giving reasons to believe for opening reassessment. However .....

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..... ch persuaded the AO to reopen the reassessment proceedings and on the basis of which additions were made were not found valid or justifiable as those additions were deleted by the Tribunal. Subsequently, an appeal preferred by the Revenue pertaining to the said additions made by the AO which were not part of "reasons to believe" and which were deleted by CIT(A) came to be heard by the Tribunal and .....

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