Usurpation of jurisdiction by AO to reopen assessment is legally untenable

Srijal Gupta Vs ITO (ITAT Amritsar)

After a thoughtful observation of the fact of the case we decided that the reopening was made u/s. 148 related to purchase of property amount to Rs.9,53,750/-. But after completion of assessment, the ld. AO had accepted the assessee’s investment and had not added any amount related to source of funds for purchase of property. Suddenly the ld. AO found that assessee is co-owner of M/s. Real Estate. As per the ld. AO, in the account opening form of the firm in the bank the PAN which was me

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