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The Appellate Tribunal upheld the reopening of assessment u/s 147 due to the assessee providing bogus accommodation loss entries. The AO had reasons to believe in the escapement of income, supported by evidence of layered transactions and unexplained deposits. The Tribunal found the AO's actions justified, as the assessee engaged in providing bogus losses and earned unaccounted brokerage income. The Tribunal rejected the assessee's contention on brokerage income calculation and upheld the addition of unaccounted income. The Tribunal also dismissed the argument against sustaining additions without cross-examination. The unexplained income received through layered transactions was deemed unexplained income. The Tribunal affirmed the decisions of the AO and CIT(A) based on the evidence presented.
The Appellate Tribunal upheld the reopening of assessment u/s 147 due to the assessee providing bogus accommodation loss entries. The AO had reasons to believe in the escapement of income, supported by evidence of layered transactions and unexplained deposits. The Tribunal found the AO's actions justified, as the assessee engaged in providing bogus losses and earned unaccounted brokerage income. The Tribunal rejected the assessee's contention on brokerage income calculation and upheld the addition of unaccounted income. The Tribunal also dismissed the argument against sustaining additions without cross-examination. The unexplained income received through layered transactions was deemed unexplained income. The Tribunal affirmed the decisions of the AO and CIT(A) based on the evidence presented.
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