The Appellate Tribunal considered the issue of reopening...

The Appellate Tribunal considered the issue of reopening assessment u/s 147 based on the belief that the investment in a property was from undisclosed income. However, the assessee provided evidence that the investment was from disclosed sources. The AO did not challenge this but made an independent addition u/s 56(2)(vii)(b) for the property's valuation difference. The Tribunal held that since the AO did not question the source of investment, he lacked jurisdiction to make the additional assessment. The AO's order u/s 144 r.w.s. 147 was deemed invalid, and the appeal was allowed.

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