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ITAT invalidated reassessment proceedings under s.147 and subsequent revision under s.263 concerning alleged accommodation entries treated as long-term capital gains. The AO's reasons for reopening were found mechanical, vague, and incomplete, lacking independent verification of information and proper inquiry. The notice under s.148 was deemed legally defective as the AO failed to specify details of alleged penny stock transactions and capital gains. Since the underlying reassessment order under s.144 r.w.s 144B was invalid, the subsequent revision proceedings initiated by Pr. CIT under s.263 were also quashed. The tribunal upheld taxpayer's additional grounds of appeal, emphasizing the importance of proper reasoning and verification in reassessment proceedings.
ITAT invalidated reassessment proceedings under s.147 and subsequent revision under s.263 concerning alleged accommodation entries treated as long-term capital gains. The AO's reasons for reopening were found mechanical, vague, and incomplete, lacking independent verification of information and proper inquiry. The notice under s.148 was deemed legally defective as the AO failed to specify details of alleged penny stock transactions and capital gains. Since the underlying reassessment order under s.144 r.w.s 144B was invalid, the subsequent revision proceedings initiated by Pr. CIT under s.263 were also quashed. The tribunal upheld taxpayer's additional grounds of appeal, emphasizing the importance of proper reasoning and verification in reassessment proceedings.
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