https://www.taxtmi.com/caselaws?id=759201 ITAT Mumbai held that reassessment proceedings under section 148 were invalid as the AO had already adjudicated the unexplained loan receipts issue during original assessment for AY 2011-12. Mere change of opinion based on investigation department report cannot justify reopening. For AY 2013-14, addition of loan and interest was deleted as AO failed to conduct independent verification despite assessee providing relevant documents including TDS deduction proof and banking channel payments. The AO relied solely on investigation report without proper verification. Both appeals decided in favor of assessee with directions to delete additions. en-us Mon, 02 Sep 2024 00:00:00 +0530 Wed, 25 Sep 2024 09:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=759201 ITAT Mumbai held that reassessment proceedings under section 148 were invalid as the AO had already adjudicated the unexplained loan receipts issue during original assessment for AY 2011-12. Mere change of opinion based on investigation department report cannot justify reopening. For AY 2013-14, addition of loan and interest was deleted as AO failed to conduct independent verification despite assessee providing relevant documents including TDS deduction proof and banking channel payments. The AO relied solely on investigation report without proper verification. Both appeals decided in favor of assessee with directions to delete additions. Case-Laws Income Tax Mon, 02 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=759201