ITAT Quashes Reassessment as Reopening Was Based Solely on Borrowed Satisfaction

Rajvi Shah Vs ITO (ITAT Ahmedabad) The assessee appealed against the order of the Commissioner of Income-tax (Appeals) for AY 2015-16. In addition to challenging an addition of ₹69,84,821, the assessee raised an additional legal ground contesting the validity of reopening of assessment under Section 147 of the Income-tax Act, 1961. Since the issue went to the root of the assessment proceedings, the Tribunal admitted the additional ground for adjudication. The assessee had originally filed a return of income on 30.09.2015 declaring total income of ₹5,64,040, and the assessment was completed...