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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.
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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