Reopening must be on the same reason on which addition is made- ₹1.30 Cr Addition Deleted

B D Cotton Associates Vs ITO (ITAT Mumbai) Reopening must be on the same reason on which addition is made- ₹1.30 Cr Addition Deleted Loan from NBFC? AO Demands ‘Source of Source’ – ITAT Says: Not in 2012!  Assessee is an Association of Persons & an NBFC registered with the RBI. It filed its return of income for A.Y. 2012-13 declaring nil income. The assessment was later reopened u/s 147 by issuing notice u/s 148 on 30.03.2019 based on information received from the Investigation Wing that M/s Agrawal Enterprise had received ₹1.30 crore from Assessee & the transaction looked s...