Mutual Fund Dividend Not Bogus u/s 68; Reopening Beyond 4 Years Held Change of Opinion; ₹39.53 Cr Deleted – ITAT Mumbai

Ramesh Purshottam Modi Vs ITO (ITAT Mumbai) Dividend from Mutual Fund Cannot be Treated as Bogus u/s 68 – Reopening Held Change of Opinion Beyond 4 Years – ₹39.53 Cr Addition Deleted – ITAT Mumbai The assessee’s case was reopened u/s 147 based on Investigation Wing information alleging dividend stripping through JM Mutual Fund schemes. The AO treated dividend of ₹44.24 crore as fictitious and made net addition of ₹39.53 crore u/s 68 r.w.s 115BBE after allowing part of the short-term capital loss. CIT(A) upheld the reassessment and addition. The ITAT observed that the original ass...