ITAT upholds validity of reopening under s.147 of the Income-tax...

ITAT upholds validity of reopening under s.147 of the Income-tax Act, finding that the AO had prima facie material (undisclosed bank account and substantial unexplained deposits during demonetisation) to infer escapement of income; CIT(A)'s detailed reasons were not controverted by the assessee and sanction under s.151 was effectively accorded. Grounds challenging jurisdictional reopening are dismissed. Reassessment was within the four-year period, so proviso to s.147 is inapplicable. Pursuant to the Explanation to s.147, AO possessed authority to examine and assess deposits beyond the original reasons; deposits in one account (partly) and entire deposits in the undisclosed account were held unexplained. Taxability of those deposits is remanded to the AO for fresh adjudication.

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