https://www.taxtmi.com/caselaws?id=782111 ITAT Delhi quashed the reassessment for AY 2012-13, holding the reopening u/s 147 invalid as it was based on incorrect facts, borrowed satisfaction from investigation reports, and mechanical approval u/s 151, relying on HC precedent. Consequently, the entire reassessment proceedings were annulled. On merits, ITAT held that the loan treated as unexplained cash credit u/s 68 was duly supported by documentation; the lender responded to notices u/ss 133(6) and 131, and interest was paid with TDS, making the addition unsustainable and liable to deletion. The ad hoc disallowance of 50% travelling expenses was deleted, as business nexus and evidence were established and books were not rejected u/s 145(3). Interest u/ss 234B and 234D was held consequential; interest u/s 234C was restricted to returned income. en-us Wed, 23 Jul 2025 00:00:00 +0530 Tue, 25 Nov 2025 08:55:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782111 ITAT Delhi quashed the reassessment for AY 2012-13, holding the reopening u/s 147 invalid as it was based on incorrect facts, borrowed satisfaction from investigation reports, and mechanical approval u/s 151, relying on HC precedent. Consequently, the entire reassessment proceedings were annulled. On merits, ITAT held that the loan treated as unexplained cash credit u/s 68 was duly supported by documentation; the lender responded to notices u/ss 133(6) and 131, and interest was paid with TDS, making the addition unsustainable and liable to deletion. The ad hoc disallowance of 50% travelling expenses was deleted, as business nexus and evidence were established and books were not rejected u/s 145(3). Interest u/ss 234B and 234D was held consequential; interest u/s 234C was restricted to returned income. Case-Laws Income Tax Wed, 23 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782111