ITAT Ahmedabad: Addition on Alleged Penny Stock Investment Deleted – No Proof of Assessee’s Own Funds

Mahendrakumar R Punjabi Vs ITO (ITAT Ahmedabad) Assessee, engaged in brokerage & share advisory, filed his return declaring income of ₹3.93 lakh for AY 2016-17. He dealt in shares primarily on behalf of clients, earning commission or “tips income.” Subsequently, the case was reopened u/s 147 on the allegation that Assessee had made unexplained investment of ₹11.27 lakh in certain shares, reportedly flagged in SEBI alerts for penny stock manipulation. Since Assessee did not respond to notices during reassessment, AO completed the proceedings ex-parte u/s 144, treating the investment...