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The ITAT set aside the additions made by the AO under sections 68 and 69C relating to unexplained cash credits, bogus commission, and bogus interest on unsecured loans, as the assessee had repaid the loans in the subsequent year and the department had accepted such repayments without making additions. The AO's reliance on unrecorded statements under section 131 and failure to demonstrate escaped income or assets as required under the fourth proviso to section 153A for reopening assessments beyond six years rendered the reassessment invalid. Since the AO did not fulfill statutory conditions for invoking extended limitation under section 153A for the eighth assessment year from the search year, the reopening was held without jurisdiction. Consequently, the ITAT allowed the assessee's appeal, quashing the additions and the reassessment proceedings.
The ITAT set aside the additions made by the AO under sections 68 and 69C relating to unexplained cash credits, bogus commission, and bogus interest on unsecured loans, as the assessee had repaid the loans in the subsequent year and the department had accepted such repayments without making additions. The AO's reliance on unrecorded statements under section 131 and failure to demonstrate escaped income or assets as required under the fourth proviso to section 153A for reopening assessments beyond six years rendered the reassessment invalid. Since the AO did not fulfill statutory conditions for invoking extended limitation under section 153A for the eighth assessment year from the search year, the reopening was held without jurisdiction. Consequently, the ITAT allowed the assessee's appeal, quashing the additions and the reassessment proceedings.
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