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ITAT held reopening assessment under section 147 invalid as AO failed to specify detailed transaction particulars regarding alleged accommodation entries. AO's reliance solely on departmental information without independent verification constituted borrowed satisfaction. The reasons provided were vague and ambiguous. On merits, regarding section 68 additions, assessee demonstrated loan repayments with supporting evidence. AO neither conducted independent verification nor issued notices under section 133(6), merely relying on statements recorded during search under section 132(4). AO's denial of cross-examination rights further weakened the case. CIT(A)'s order directing deletion of additions upheld, ruling in assessee's favor.
ITAT held reopening assessment under section 147 invalid as AO failed to specify detailed transaction particulars regarding alleged accommodation entries. AO's reliance solely on departmental information without independent verification constituted borrowed satisfaction. The reasons provided were vague and ambiguous. On merits, regarding section 68 additions, assessee demonstrated loan repayments with supporting evidence. AO neither conducted independent verification nor issued notices under section 133(6), merely relying on statements recorded during search under section 132(4). AO's denial of cross-examination rights further weakened the case. CIT(A)'s order directing deletion of additions upheld, ruling in assessee's favor.
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