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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.
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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