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ITAT held that the reopening of assessment u/s. 147 was invalid because the AO relied only on unspecified "information" from an internal portal without furnishing the actual material or reasons to the assessee, thereby failing to demonstrate subjective satisfaction or provide the basis for reopening. The AO did not correlate the undisclosed information with the assessee's transactions nor elicit statements based on that information. Consequently, additions u/s. 68 were untenable: the assessee produced purchase particulars, demat records and exchange sale documents which the AO neither controverted nor discredited in the assessment order. For these reasons the ITAT set aside the reopening and allowed the assessee's appeal.
ITAT held that the reopening of assessment u/s. 147 was invalid because the AO relied only on unspecified "information" from an internal portal without furnishing the actual material or reasons to the assessee, thereby failing to demonstrate subjective satisfaction or provide the basis for reopening. The AO did not correlate the undisclosed information with the assessee's transactions nor elicit statements based on that information. Consequently, additions u/s. 68 were untenable: the assessee produced purchase particulars, demat records and exchange sale documents which the AO neither controverted nor discredited in the assessment order. For these reasons the ITAT set aside the reopening and allowed the assessee's appeal.
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