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ITAT ruled against reopening of assessment under s.147 beyond four-year limitation period, finding no independent application of mind by AO or CIT(A). The tribunal rejected additions under s.68 regarding alleged accommodation entries, as the assessee provided sufficient evidence including ledger copies, invoices, and transport details for genuine business transactions. The revenue authorities' reliance on Investigation Unit's information without allowing cross-examination was deemed improper. The tribunal also dismissed allegations of unexplained commission payments for accommodation entries, noting the transactions were legitimate sales receipts from previous year, not undisclosed loans or share capital. Additions made purely on third-party information without corroborating evidence were set aside.
ITAT ruled against reopening of assessment under s.147 beyond four-year limitation period, finding no independent application of mind by AO or CIT(A). The tribunal rejected additions under s.68 regarding alleged accommodation entries, as the assessee provided sufficient evidence including ledger copies, invoices, and transport details for genuine business transactions. The revenue authorities' reliance on Investigation Unit's information without allowing cross-examination was deemed improper. The tribunal also dismissed allegations of unexplained commission payments for accommodation entries, noting the transactions were legitimate sales receipts from previous year, not undisclosed loans or share capital. Additions made purely on third-party information without corroborating evidence were set aside.
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