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The ITAT held that the assessing officer's addition to the assessee's income on account of purported "additional capital" was unjustified. The tribunal found that the information from the Annual Information Report (AIR) relied upon to invoke section 147 was already reflected in and duly declared in the assessee's books of account, negating any basis for reopening. Consequently, the reassessment was held invalid and the assessment order under section 147 was quashed. The assessee's appeal was allowed, with the effect that the impugned income addition is set aside and no further liability arises from the disputed AIR-based allegation.
The ITAT held that the assessing officer's addition to the assessee's income on account of purported "additional capital" was unjustified. The tribunal found that the information from the Annual Information Report (AIR) relied upon to invoke section 147 was already reflected in and duly declared in the assessee's books of account, negating any basis for reopening. Consequently, the reassessment was held invalid and the assessment order under section 147 was quashed. The assessee's appeal was allowed, with the effect that the impugned income addition is set aside and no further liability arises from the disputed AIR-based allegation.
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