Reopening of assessment for contingent nature of addition unsustainable

DCIT Vs G.K. Ispat Pvt. Ltd. (ITAT Kolkata) ITAT Kolkata held that addition cannot be made on protective basis in the reopened assessment proceeding as the assessment cannot be reopened for a contingent nature of addition. Facts- During the course of original assessment proceedings, the AO examined the issue of an interest-bearing loan taken from M/s Gaurav Rose Real Estate Pvt. Ltd.of Rs. 14.11 crores by calling for various details and evidence which were duly furnished by the assessee. The said transaction of Rs. 14.11 crores was explained by the assessee before the AO and assessment was als...