Assessment Reopening Quashed Due to Defective Reasons and Roving Inquiry

Sapna Nainesh Jatania Vs ITO (ITAT Rajkot) Reopening Quashed: Reasons Show Only Verification & Borrowed Satisfaction- Wrong Facts, No Enquiry: Tribunal Strikes Down Verification-Based Reopening Assessee’s appeals for AYs 2011-12 & 2012-13 involved additions of Rs.8,60,444 treating penny-stock sale proceeds of Gemstone Investment Ltd as unexplained u/s 69 pursuant to reassessment u/s 147 r.w.s 144. CIT(A)/NFAC had remanded the case to AO without deciding Assessee’s jurisdictional ground against reopening. Tribunal first condoned 55-day delay after finding the affidavit explanation r...