https://www.taxtmi.com/caselaws?id=784435 Reopening under ss. 147/151 was upheld because the AO acted on credible Investigation Wing material identifying the assessee as a beneficiary of accommodation entries and disposed of objections by examining the record; the challenge that approval under s. 151 was mechanical was rejected, resulting in dismissal of the reopening grounds. Addition under s. 68 for unsecured loans was deleted because, for the relevant AY, the Finance Act, 2022 second proviso (requiring "source of source") was inapplicable and, in any event, the assessee substantiated the creditor's funds through bank statements and repayments were through banking channels; further, reliance on third-party statements without furnishing them or allowing cross-examination violated natural justice, vitiating the addition. en-us Wed, 31 Dec 2025 00:00:00 +0530 Mon, 05 Jan 2026 08:04:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784435 Reopening under ss. 147/151 was upheld because the AO acted on credible Investigation Wing material identifying the assessee as a beneficiary of accommodation entries and disposed of objections by examining the record; the challenge that approval under s. 151 was mechanical was rejected, resulting in dismissal of the reopening grounds. Addition under s. 68 for unsecured loans was deleted because, for the relevant AY, the Finance Act, 2022 second proviso (requiring "source of source") was inapplicable and, in any event, the assessee substantiated the creditor's funds through bank statements and repayments were through banking channels; further, reliance on third-party statements without furnishing them or allowing cross-examination violated natural justice, vitiating the addition. Case-Laws Income Tax Wed, 31 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784435