https://www.taxtmi.com/caselaws?id=751871 The ITAT Ahmedabad dismissed the assessee's challenge to assessment reopening under section 147, holding that since the assessee failed to seek reasons for reopening during assessment or appellate proceedings, relief on technical grounds was not tenable, following GKN Driveshaft precedent. However, the tribunal allowed appeals regarding additions under section 69C. For capital introduced by a partner, the tribunal ruled that once the partner explained the source, any unexplained amounts should be assessed in the partner's individual hands, not the firm's. For unsecured loans, the tribunal found the assessee discharged the primary onus by proving identity, genuineness, and creditworthiness of the lender, and without adequate material, the addition was unjustified. en-us Wed, 24 Apr 2024 00:00:00 +0530 Sat, 27 Apr 2024 07:32:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=751871 The ITAT Ahmedabad dismissed the assessee's challenge to assessment reopening under section 147, holding that since the assessee failed to seek reasons for reopening during assessment or appellate proceedings, relief on technical grounds was not tenable, following GKN Driveshaft precedent. However, the tribunal allowed appeals regarding additions under section 69C. For capital introduced by a partner, the tribunal ruled that once the partner explained the source, any unexplained amounts should be assessed in the partner's individual hands, not the firm's. For unsecured loans, the tribunal found the assessee discharged the primary onus by proving identity, genuineness, and creditworthiness of the lender, and without adequate material, the addition was unjustified. Case-Laws Income Tax Wed, 24 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=751871