https://www.taxtmi.com/caselaws?id=761546 ITAT Mumbai held that reopening under section 147 was invalid where AO relied on presumptions about lender company's capacity without tangible evidence. The assessee had adequately explained property investment sources through loan from M/s. Sneha Ferromet Pvt. Ltd., supported by confirmations, bank statements, and company returns. Since original assessment under section 143(3)/153A was completed after examining these documents without adverse findings, and no new material emerged post-assessment, the reopening lacked jurisdiction. The addition based on presumed inadequate turnover of lending company was deleted as onus was discharged. en-us Mon, 14 Oct 2024 00:00:00 +0530 Tue, 12 Nov 2024 08:53:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=761546 ITAT Mumbai held that reopening under section 147 was invalid where AO relied on presumptions about lender company's capacity without tangible evidence. The assessee had adequately explained property investment sources through loan from M/s. Sneha Ferromet Pvt. Ltd., supported by confirmations, bank statements, and company returns. Since original assessment under section 143(3)/153A was completed after examining these documents without adverse findings, and no new material emerged post-assessment, the reopening lacked jurisdiction. The addition based on presumed inadequate turnover of lending company was deleted as onus was discharged. Case-Laws Income Tax Mon, 14 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=761546