Delhi ITAT Quashes Reopening – Two Different Reasons & Post-Facto Approval Fatal

Avon Containners Pvt. Ltd Vs ACIT (ITAT Delhi) Assessee filed return declaring income of ₹46,06,870 which was originally assessed u/s 143(3) at ₹50,42,370. Subsequently, AO reopened the case by issuing notice u/s 148 on 29.03.2019, & reassessment was completed on 14.11.2019 determining income at ₹1,05,42,370 with an addition of ₹55 lakh u/s 68 towards alleged accommodation entries from M/s Rising Portfolio India Pvt. Ltd. (₹30 lakh) & M/s Secure Portfolios India Pvt. Ltd. (₹25 lakh). CIT(A) upheld reassessment, holding that approval of reopening was validly granted by PCIT ...