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Reopening of assessment based on credible information from Investigation Wing was invalid. Addition u/s 68 regarding unaccounted money ploughed back as share capital and premium was made solely relying on retracted statement without independent inquiry by Assessing Officer (AO). Reasons for reopening lacked live nexus, were based on borrowed satisfaction, and had infirmities and mismatch in amounts and names of investors. AO failed to verify authenticity of information and evidence adduced by assessee. Addition made on mere suspicion and conjectures without legal basis. Appellate authorities rightly quashed addition and reopening, as AO did not bring out independent application of mind, and reasons recorded were fragile and factually incorrect.
Reopening of assessment based on credible information from Investigation Wing was invalid. Addition u/s 68 regarding unaccounted money ploughed back as share capital and premium was made solely relying on retracted statement without independent inquiry by Assessing Officer (AO). Reasons for reopening lacked live nexus, were based on borrowed satisfaction, and had infirmities and mismatch in amounts and names of investors. AO failed to verify authenticity of information and evidence adduced by assessee. Addition made on mere suspicion and conjectures without legal basis. Appellate authorities rightly quashed addition and reopening, as AO did not bring out independent application of mind, and reasons recorded were fragile and factually incorrect.
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