Reopening Quashed as Original Reason for 147 Fails – No Other Additions Can Survive

Rakesh Arora Vs ITO (ITAT Delhi) When the Reason Falls, the Case Falls: Rs. 3.14 Cr Trigger Proves False — ITAT Delhi Quashes Whole 147 The reassessment for AY 2012–13 was triggered solely on the allegation that the assessee had received accommodation entries of ₹3,14,16,000 from M/s Shreyas International. However, at the time of completing reassessment, the AO enhanced the figure and made an addition of ₹3,84,04,298 under Section 69A, along with other loan-related additions. On appeal, the CIT(A) categorically held that the impugned amount was not unexplained money, but merely the ret...