The Appellate Tribunal addressed the validity of reopening ...

Validity of reopening of assessment u/s 147 upheld. Addition u/s 69A rejected. Assessee's explanations deemed sufficient.

Case Laws     Income Tax

June 6, 2024

The Appellate Tribunal addressed the validity of reopening assessment under section 147 and addition under section 69A. The Tribunal held that the AO had sufficient information from DDIT indicating unexplained bank deposits, justifying the belief of income escapement. The assessee's claim of lack of AO's consideration was unsubstantiated and rejected. The Tribunal also dismissed the limitation argument due to the extension granted by TOLA. Regarding the addition under section 69A for cash deposits, the Tribunal found the assessee's explanations and submitted documents credible, highlighting that the books were audited and no discrepancies were reported. As the revenue failed to challenge the evidence, the Tribunal ruled in favor of the assessee, deeming the addition by the AO as unsustainable.

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