Reopening U/s 147 quashed – Borrowed satisfaction mechanical approval U/s 151 invalid; sale of investments cannot be taxed U/s 68 – ITAT Kolkata

Gulmohar Towers Private Limited Vs ITO (ITAT Kolkata)

In Gulmohar Towers Pvt. Ltd. vs ITO (A.Y. 2011-12), reassessment was initiated alleging accommodation entries and addition of ₹43.32 crore based on investigation wing information relating to sale of shares. The ITAT observed that the reasons recorded were vague, generic and lacked independent application of mind, merely reproducing investigation inputs without establishing how income had escaped assessment. The Tribunal hel

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