Mere Retracted statement cannot form the basis of reopening

In the present case, from the reasons recorded by the AO as reproduced hereinabove, we observe that the AO went on to initiate reassessment proceedings u/s 147 and 148 of the Act on the basis of retracted statement of Shri Subhash Gupta without making any further inquiry and investigation. From bare reading of reasons recorded, we also observe that the AO went on to reopen the assessment with a genuine intention to make protective addition pertaining to the accommodation entries alleged to be provided by the appellant company and at the same time, we notice that

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