https://www.taxtmi.com/caselaws?id=464296 ITAT DELHI - AT held the reopening under section 147 valid: the AO had tangible material (undeclared cash deposits and no return) and the assessee did not respond to initial queries, justifying prima facie belief of escapement. On merits, the tribunal deleted the addition under section 69A r/w 115BBE: the assessee produced a gift deed, the donor's bank statement and the donor's death certificate explaining non-response to summons, and the AO failed to make broader inquiries into the donor's creditworthiness or heirs before sustaining the addition. en-us Wed, 19 Oct 2022 00:00:00 +0530 Thu, 16 Oct 2025 22:05:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464296 ITAT DELHI - AT held the reopening under section 147 valid: the AO had tangible material (undeclared cash deposits and no return) and the assessee did not respond to initial queries, justifying prima facie belief of escapement. On merits, the tribunal deleted the addition under section 69A r/w 115BBE: the assessee produced a gift deed, the donor's bank statement and the donor's death certificate explaining non-response to summons, and the AO failed to make broader inquiries into the donor's creditworthiness or heirs before sustaining the addition. Case-Laws Income Tax Wed, 19 Oct 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464296