https://www.taxtmi.com/caselaws?id=758712 ITAT Pune upheld the AO's reopening of assessment under section 147 despite CIT(A)'s finding that reasons merely stated "needs to be verified." The tribunal held that AO had properly recorded satisfaction regarding income escapement of Rs. 1,68,24,239/- and suppressed gross profit based on ledger analysis. Relying on Raymond Woollen Mills SC precedent, the tribunal emphasized that reasons must be read in totality and mere mention of "verification" doesn't vitiate entire reasoning. The AO demonstrated prima-facie satisfaction based on material evidence of purchase-sales discrepancies. Decision favored revenue, reversing CIT(A)'s order. en-us Fri, 30 Aug 2024 00:00:00 +0530 Tue, 17 Sep 2024 11:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=758712 ITAT Pune upheld the AO's reopening of assessment under section 147 despite CIT(A)'s finding that reasons merely stated "needs to be verified." The tribunal held that AO had properly recorded satisfaction regarding income escapement of Rs. 1,68,24,239/- and suppressed gross profit based on ledger analysis. Relying on Raymond Woollen Mills SC precedent, the tribunal emphasized that reasons must be read in totality and mere mention of "verification" doesn't vitiate entire reasoning. The AO demonstrated prima-facie satisfaction based on material evidence of purchase-sales discrepancies. Decision favored revenue, reversing CIT(A)'s order. Case-Laws Income Tax Fri, 30 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=758712