Reopening not justified as reasons recorded remained speculative

Sunrise Propbuild Pvt. Ltd. Vs ACIT (ITAT Delhi) ITAT Delhi held that without a clear and direct connection between the facts and the alleged escapement of income, the reasons recorded remains speculative, therefore, the reopening cannot be justified. Accordingly, appeal allowed to that extent. Facts- The case of the Assessee was selected for re­assessment under Section 147 of the Act. The A.O. completed the assessment proceedings u/s 147 r.w. Section 143(3) of the Act vide order dated 28/12/2018 by making an addition of Rs. 2,76,00,000/- as commission income. Aggrieved by the assessment ord...