Section 69A Addition Deleted & Reopening Quashed – No Ownership of Money & Borrowed Satisfaction

DCIT Vs Rajan Kumar (ITAT Delhi)

The ITAT Delhi dismissed the Revenue’s appeal and allowed the assessee’s cross-objection in a case involving alleged accommodation entries of ₹1.83 crore. The Tribunal upheld the NFAC’s finding that section 69A could not be invoked since the assessee was never found to be owner or in possession of any unaccounted money or valuable article; mere reliance on investigation statements was insufficient. It was also noted that the assessee had already been assessed earlier by estimating

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