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The Appellate Tribunal considered the issue of reopening assessment u/s 147 regarding unexplained cash credit u/s 68. It was held that the Assessing Officer must have a live nexus between the information possessed and the belief formed. The reasons provided by the AO only mentioned the nature of information and listed 13 companies without proper analysis. The AO did not inquire about the nature of these companies or how the money reached the assessee. The Tribunal found that the AO did not apply his mind and relied on information without proper examination, leading to the quashing of the assessment reopening. The appeal of the assessee was allowed.
The Appellate Tribunal considered the issue of reopening assessment u/s 147 regarding unexplained cash credit u/s 68. It was held that the Assessing Officer must have a live nexus between the information possessed and the belief formed. The reasons provided by the AO only mentioned the nature of information and listed 13 companies without proper analysis. The AO did not inquire about the nature of these companies or how the money reached the assessee. The Tribunal found that the AO did not apply his mind and relied on information without proper examination, leading to the quashing of the assessment reopening. The appeal of the assessee was allowed.
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