Reopening Assessment Under Section 147 Invalid When Information Already Available During Original Section 143(3) Assessment

ITAT dismissed the Revenue's appeal concerning reopening of assessments under s.147 and additions under s.68 for alleged bogus share application money and unsecured loans. The Tribunal found that the AO mechanically issued s.148 notice based on information from the Investigation Wing without proper application of mind, despite all information being available in the previously completed s.143(3) assessment. Regarding share capital, the assessee had discharged its onus under s.68 by providing documentation establishing identity, creditworthiness, and genuineness of transactions. For unsecured loans, the Tribunal noted their repayment within a short period, and that the Revenue's case relied on a retracted statement of Mukesh Banka, which could not form the basis for additions per jurisdictional precedent. .....

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