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The Appellate Tribunal upheld the validity of reopening assessment proceedings u/s 147 and issuing notice u/s 148 based on information from the Annual Information Return (AIR) about substantial cash deposits in the assessee's bank accounts. The Tribunal ruled that the Assessing Officer (AO) had sufficient tangible material to reopen the case and the assessee's contention regarding non-supply of AIR information details was rejected. Regarding the additions made u/ss 69A and 69 for unexplained money and investments, the Tribunal partially allowed the assessee's grounds. Considering the decision in CIT vs. Samir Synthetics Mill, the Tribunal estimated 10% of the cash credits of Rs. 43,99,215 and other credits of Rs. 1.70 lacs as the assessee's reasonable income to avoid revenue leakage, instead of treating the entire transactions as income.
The Appellate Tribunal upheld the validity of reopening assessment proceedings u/s 147 and issuing notice u/s 148 based on information from the Annual Information Return (AIR) about substantial cash deposits in the assessee's bank accounts. The Tribunal ruled that the Assessing Officer (AO) had sufficient tangible material to reopen the case and the assessee's contention regarding non-supply of AIR information details was rejected. Regarding the additions made u/ss 69A and 69 for unexplained money and investments, the Tribunal partially allowed the assessee's grounds. Considering the decision in CIT vs. Samir Synthetics Mill, the Tribunal estimated 10% of the cash credits of Rs. 43,99,215 and other credits of Rs. 1.70 lacs as the assessee's reasonable income to avoid revenue leakage, instead of treating the entire transactions as income.
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