Re-assessment u/s 147 - unexplained borrowal of funds as well as deployment of such funds - disallowance...

Re-assessment u/s 147 - unexplained borrowal of funds as well as deployment of such funds - disallowance u/s 36(1)(iii) - no original assessment u/s 143(3) hence the restriction imposed by the proviso to Section 147 will not come to the rescue - ITAT after considering financial statements, the concept of same management and chain holding of shares and tax adjustments, agreed with the CIT(A)'s findings - no substantial question of law arises - reassessment upheld .....

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