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The ITAT upheld reassessment under s.147, finding the AO's formation of belief was based on independent, cogent material from the Investigation Wing and not on borrowed satisfaction; the reopening was procedurally and substantively justified. The Tribunal sustained the AO's s.68 addition treating alleged LTCG as unexplained income, noting the assessee failed to discharge the onus to prove genuineness of massive acquisition of shares in an entity lacking commercial and financial credentials. Documentary proofs alone (contract notes, demat extracts, bank payments) were insufficient in light of surrounding circumstances, manipulated trading patterns and absence of commercial substance, leading the ITAT to dismiss the assessee's appeal.
The ITAT upheld reassessment under s.147, finding the AO's formation of belief was based on independent, cogent material from the Investigation Wing and not on borrowed satisfaction; the reopening was procedurally and substantively justified. The Tribunal sustained the AO's s.68 addition treating alleged LTCG as unexplained income, noting the assessee failed to discharge the onus to prove genuineness of massive acquisition of shares in an entity lacking commercial and financial credentials. Documentary proofs alone (contract notes, demat extracts, bank payments) were insufficient in light of surrounding circumstances, manipulated trading patterns and absence of commercial substance, leading the ITAT to dismiss the assessee's appeal.
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