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ITAT upheld validity of reopening, finding that approval under s.151 was recorded on the ITBA on 29.03.2018 and thereby authorised issuance of notice under s.148, rejecting the assessee's challenge to reopening. On merits, ITAT recognised PBPT adjudication holding the transaction benami and identifying multiple beneficial owners; consequently ITAT held the entire addition could not be charged solely to the assessee under s.69 and directed restoration to the AO for re-adjudication and allocation of unexplained investment among joint beneficial owners in accordance with PBPT orders. The appellate order of CIT(A) was set aside, and reliance on incomplete VSVS filings was held not to be a conclusive admission.
ITAT upheld validity of reopening, finding that approval under s.151 was recorded on the ITBA on 29.03.2018 and thereby authorised issuance of notice under s.148, rejecting the assessee's challenge to reopening. On merits, ITAT recognised PBPT adjudication holding the transaction benami and identifying multiple beneficial owners; consequently ITAT held the entire addition could not be charged solely to the assessee under s.69 and directed restoration to the AO for re-adjudication and allocation of unexplained investment among joint beneficial owners in accordance with PBPT orders. The appellate order of CIT(A) was set aside, and reliance on incomplete VSVS filings was held not to be a conclusive admission.
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