Co-operative society's mandatory reserve and share capital fixed deposits with banks-interest treated as business income under 80P(2)(a)(iii) deductio...
Income tax reassessment reopening after four years on investigation tip, without s.147 proviso disclosure failure, struck down as borrowed satisfactio...
Reopening was upheld since approval u/s 151 validly relied on recorded "reasons to believe" founded on specific third-party RTGS information indicating alleged bogus purchases/expenses; hence reassessment proceedings were not vitiated. Addition u/s 69 was deleted because s.69 applies only where unrecorded "investments" are found, and alleged bogus purchases recorded in the books do not constitute unrecorded investments; absent any stock/inventory discrepancy or rejection of books, and with no allegation that purchase funding was outside known book sources, the assessee's onus to explain nature and source stood satisfied. Appeal allowed. - ITAT
Reopening was upheld since approval u/s 151 validly relied on recorded "reasons to believe" founded on specific third-party RTGS information indicating alleged bogus purchases/expenses; hence reassessment proceedings were not vitiated. Addition u/s 69 was deleted because s.69 applies only where unrecorded "investments" are found, and alleged bogus purchases recorded in the books do not constitute unrecorded investments; absent any stock/inventory discrepancy or rejection of books, and with no allegation that purchase funding was outside known book sources, the assessee's onus to explain nature and source stood satisfied. Appeal allowed. - ITAT
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