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Borrowed Satisfaction from Insight Portal Invalid; Re-opening Section 68 Addition Quashed
Case Law Details
- Case Name
- Devkrupa International Vs ACIT (ITAT Ahmedabad)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2017-18
- Courts
- All ITAT, ITAT Ahmedabad
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Devkrupa International Vs ACIT (ITAT Ahmedabad)
The ITAT, Ahmedabad Bench held that re-opening based solely on Insight Portal inputs, without independent application of mind, is invalid in law. In this case (AY 2017-18), the AO issued s.148 notice dated 29.03.2021 alleging accommodation entries of ₹71.42 lakh from M/s Kasturi Commodities Pvt. Ltd., and completed reassessment u/s 147 r.w.s. 144B, making addition u/s 68.
The Tribunal found the reasons recorded to be mechanical and generic—they merely reproduced portal information, did not disclose the source or nature of mat...
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