ITAT remits un-reconciled Vienna bank payments case for fresh assessment after forensic audit without proper rebuttal opportunity

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....ITAT set aside CIT(A)'s order deleting additions towards un-reconciled payments from Vienna bank account and remitted matter to AO for fresh consideration. Tribunal found valid nexus between reopening reasons based on confession statement and escaped income, noting appellant's admission of Rs. 1230 crores understated liability. AO's additions were based on KPMG forensic audit report without providing copy to assessee for rebuttal. Since related company's assessment was set aside by High Court for considering re-casted books of accounts, and intra-group transactions would impact appellant's income, fresh assessment required after considering re-casted accounts and forensic audit findings. Both assessee's and revenue's appeals allowed for statistical purposes.....