Tangible material and valid sanction sustained the reopening, while uncontroverted commission evidence upheld the addition.

Reassessment under sections 147/148 was upheld because the reopening was founded on tangible material and the approval under section 151 was granted after due consideration, so the challenge to validity failed. The addition of commission income was also sustained because the reopening material indicated a commission arrangement and payment linked to the assessee, while no request was made for cross-examination of the concerned person or for the seized material. The appeal therefore failed on both the reopening issue and the merits of the addition, and the assessment was upheld.

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Issues: (i) Whether the reassessment proceedings under sections 147/148 of the Income-tax Act, 1961 were invalid for want of tangible material and for allegedly mechanical approval under section 151; (ii) Whether the addition of commission income of Rs. 5,05,000 was unsustainable on merits.

Issue (i): Whether the reassessment proceedings under sections 147/148 of the Income-tax Act, 1961 were invalid for want of tangible material and for allegedly mechanical approval under section 151.

Analysis: The record showed that the assessing authority had relied upon tangible material while recording reasons for reopening, and the prescribed authority had granted approval after detailed consideration. The challenge to the validity of the reopening and the sanction was therefore not accepted.

Conclusion: The legal objection to reassessment was rejected and the reopening was held valid.

Issue (ii): Whether the addition of commission income of Rs. 5,05,000 was unsustainable on merits.

Analysis: The reopening material indicated a commission arrangement and payment in relation to the assessee. The assessee neither sought cross-examination of the concerned person nor asked for the seized material. On that basis, the challenge to the addition was not found acceptable.

Conclusion: The addition of commission income was sustained and the assessee's challenge failed.

Final Conclusion: The appeal failed in both law and on merits, and the assessment and addition were upheld.

Ratio Decidendi: Reassessment is valid where it is founded on tangible material and duly approved under section 151, and an addition may be sustained where the underlying material remains uncontroverted and no request for cross-examination is made.

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