https://www.taxtmi.com/caselaws?id=426439 ITAT RAIPUR - AT quashed reopening and reassessment under s.147/143(3) for lack of A.O.'s bona fide belief, for reopening beyond the four-year proviso where no failure to disclose was alleged, and for impermissible change of opinion. The Tribunal found the reasons recorded merely echoed information from DDIT without independent application of mind. Recharacterisation of earlier-accepted cash sales as unexplained credits under s.68 was held unsustainable (double jeopardy and inconsistent approach), and the deletion of the s.68 addition was upheld. Decision against revenue. en-us Thu, 04 Aug 2022 00:00:00 +0530 Sat, 11 Oct 2025 13:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=426439 ITAT RAIPUR - AT quashed reopening and reassessment under s.147/143(3) for lack of A.O.'s bona fide belief, for reopening beyond the four-year proviso where no failure to disclose was alleged, and for impermissible change of opinion. The Tribunal found the reasons recorded merely echoed information from DDIT without independent application of mind. Recharacterisation of earlier-accepted cash sales as unexplained credits under s.68 was held unsustainable (double jeopardy and inconsistent approach), and the deletion of the s.68 addition was upheld. Decision against revenue. Case-Laws Income Tax Thu, 04 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=426439