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 under s.147 was held invalid because the recorded reasons did not demonstrate a clear, direct nexus between the stated transaction discrepancies and any escapement of income, rendering the belief speculative; accordingly, the reassessment was quashed. Independently, the s.68 addition for alleged unexplained credits was deleted as the taxpayer discharged the statutory onus by furnishing cogent documentary evidence establishing identity, creditworthiness, and genuineness of the credit, and the loan was also repaid; the appellate confirmation of the addition was set aside. - ITAT
Reopening under s.147 was held invalid because the recorded reasons did not demonstrate a clear, direct nexus between the stated transaction discrepancies and any escapement of income, rendering the belief speculative; accordingly, the reassessment was quashed. Independently, the s.68 addition for alleged unexplained credits was deleted as the taxpayer discharged the statutory onus by furnishing cogent documentary evidence establishing identity, creditworthiness, and genuineness of the credit, and the loan was also repaid; the appellate confirmation of the addition was set aside. - ITAT
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