https://www.taxtmi.com/caselaws?id=753933 ITAT Kolkata allowed the assessee's appeal and quashed the assessment framed u/s 143(3) r/w 147. The AO reopened assessment u/s 147 based on reasons recorded u/s 148(2) regarding accommodation entries from shell entities, but made no addition for the recorded reasons. Instead, addition was made u/s 69C for bogus purchases on different grounds altogether. The tribunal held this assessment invalid as additions cannot be made on issues other than those specified in reopening reasons. Additionally, section 69C was wrongly applied since the assessee had disclosed purchases in books with explained sources, making the expenditure fully explained rather than unexplained. en-us Tue, 11 Jun 2024 00:00:00 +0530 Thu, 13 Jun 2024 08:11:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=753933 ITAT Kolkata allowed the assessee's appeal and quashed the assessment framed u/s 143(3) r/w 147. The AO reopened assessment u/s 147 based on reasons recorded u/s 148(2) regarding accommodation entries from shell entities, but made no addition for the recorded reasons. Instead, addition was made u/s 69C for bogus purchases on different grounds altogether. The tribunal held this assessment invalid as additions cannot be made on issues other than those specified in reopening reasons. Additionally, section 69C was wrongly applied since the assessee had disclosed purchases in books with explained sources, making the expenditure fully explained rather than unexplained. Case-Laws Income Tax Tue, 11 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=753933