ITAT held that the Pr.CIT's revision u/s 263 and consequential...

ITAT held that the Pr.CIT's revision u/s 263 and consequential addition u/s 68 for unexplained cash credits were unsustainable. The assessee had furnished complete evidences establishing identity, genuineness and creditworthiness of share subscribers, including responses to notices u/s 133(6) and compliance with summons u/s 131, with payments made through banking channels. Mere non-traceability of some subscribers at later dates could not justify addition u/s 68 in absence of contrary material. ITAT further held that reassessment proceedings initiated u/s 147/148 were barred by limitation, as the original assessment u/s 143(3) had examined and accepted the disclosed transactions and losses, leaving no failure to fully and truly disclose material facts. The reassessment was quashed and the assessee's appeal allowed.

---