https://www.taxtmi.com/caselaws?id=753818 The ITAT Kolkata quashed the reopening of assessment under section 147 for unexplained cash credit under section 68. The AO failed to establish a live nexus between possessed information and belief formation regarding income escapement. The AO merely reproduced details of 13 companies from MCA data and ITD module, labeling them shell companies without independent inquiry. The AO did not analyze which specific companies received money from the assessee or trace the layering process. The tribunal found no application of mind by the AO, who relied on portal information without analytical examination. The assessee's appeal was allowed. en-us Fri, 07 Jun 2024 00:00:00 +0530 Tue, 11 Jun 2024 07:57:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=753818 The ITAT Kolkata quashed the reopening of assessment under section 147 for unexplained cash credit under section 68. The AO failed to establish a live nexus between possessed information and belief formation regarding income escapement. The AO merely reproduced details of 13 companies from MCA data and ITD module, labeling them shell companies without independent inquiry. The AO did not analyze which specific companies received money from the assessee or trace the layering process. The tribunal found no application of mind by the AO, who relied on portal information without analytical examination. The assessee's appeal was allowed. Case-Laws Income Tax Fri, 07 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=753818