Fresh verification of alleged investment required where ex parte reassessment lacked proper inquiry and supporting document review.

Reassessment based on an alleged investment required fresh verification because the assessment was made ex parte on received information without checking the purchase deed or properly examining the actual year and fact of investment. The assessee also failed to participate effectively or place relevant documents before the lower authorities. In view of these contributory lapses, the merits of the addition could not be conclusively determined at this stage, and the assessment and appellate orders were set aside with the matter remitted to the AO for fresh examination.

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Issues: Whether the reassessment and consequential addition based on the alleged investment required fresh examination and whether the matter should be restored to the Assessing Officer.

Analysis: The assessment was made ex parte on the basis of information received, without verification of the purchase deed or proper inquiry into the actual year and fact of investment. At the same time, the assessee also failed to participate before the Assessing Officer and did not effectively place the relevant documents before the first appellate authority. In view of this contributory lapse on both sides, the record did not justify a conclusive adjudication on the merits of the addition at this stage.

Conclusion: The assessment and appellate orders were set aside and the matter was remitted to the Assessing Officer for fresh examination of the investment issue.

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