Penny Stock Addition u/s 68 Set Aside; Reopening Held Invalid for lack of Mind Application

Kalpana Ramesh Jain Vs DCIT (ITAT Mumbai) The assessee challenged reassessment for AYs 2015-16 to 2017-18 where alleged LTCG from Toyam Industries shares was treated as unexplained cash credit u/s 68. ITAT quashed reassessment across all three years primarily on jurisdictional defects including defective reasons, limitation issues and incorrect sanction authority. For AY 2015-16 & 2016-17, Tribunal held that reopening was based on factually incorrect and contradictory reasons — AO wrongly treated assessee as accommodation entry provider while later treating her as beneficiary. Reasons al...