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The ITAT upheld the validity of the reopening notice issued under section 148 within the six-year limitation period prescribed by section 149(1)(b), despite the notice being served after issuance. The tribunal emphasized that issuance within the prescribed period suffices, and service may occur subsequently. The reasons recorded for reopening were held valid, with the AO having followed due process under section 144. However, regarding unexplained investment under section 69, the AO's addition was set aside because the AO failed to independently verify the lenders' identities or documents, despite the assessee discharging the initial onus of explanation. The AO was directed to delete the addition, as the investment could not be treated as unexplained without proper verification. Grounds challenging the reopening and reassessment proceedings were dismissed, while the addition under section 69 was reversed.
The ITAT upheld the validity of the reopening notice issued under section 148 within the six-year limitation period prescribed by section 149(1)(b), despite the notice being served after issuance. The tribunal emphasized that issuance within the prescribed period suffices, and service may occur subsequently. The reasons recorded for reopening were held valid, with the AO having followed due process under section 144. However, regarding unexplained investment under section 69, the AO's addition was set aside because the AO failed to independently verify the lenders' identities or documents, despite the assessee discharging the initial onus of explanation. The AO was directed to delete the addition, as the investment could not be treated as unexplained without proper verification. Grounds challenging the reopening and reassessment proceedings were dismissed, while the addition under section 69 was reversed.
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