₹1 Cr Penny Stock Addition u/s 69A Deleted – Reopening Based on Borrowed Satisfaction & No Assessee-Specific Evidence: ITAT Ahmedabad

Nirman Vs DCIT (ITAT Ahmedabad) ₹1 Cr Penny Stock / Accommodation Entry Addition u/s 69A Deleted – Reopening Held Based on Borrowed Satisfaction & No Assessee-Specific Evidence – ITAT Ahmedabad The AO reopened assessment alleging that the assessee received ₹1 crore accommodation entry linked to search proceedings against alleged entry operators. Addition u/s 69A was made based largely on investigation reports and general modus operandi without identifying specific transaction trail or material linking the assessee. CIT(A) mechanically confirmed the addition. ITAT held that reop...