ITAT held that once the Assessing Officer (AO) is satisfied with ...

Income Tax Reassessment Limited to Original Grounds: AO Cannot Expand Scope Beyond Initially Recorded Reasons for Reopening Case

April 10, 2025

Case Laws     Income Tax     AT

ITAT held that once the Assessing Officer (AO) is satisfied with the reasons recorded for reopening the case and abstains from making additions on the specific grounds initially cited, the AO's jurisdiction terminates. The tribunal found that the AO cannot proceed to tax additional income that came to notice during reassessment proceedings beyond the original reasons for reopening the case. Relying on judicial precedent, the tribunal concluded that after explaining the initially suspected escaped income, the AO loses jurisdiction to make further additions. Consequently, the assessee's primary ground of challenge was allowed, effectively limiting the scope of reassessment to the originally identified potential tax discrepancy.

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