Third-party bank information alone cannot justify reassessment; cash deposit addition also failed when the relevant year was unverified.

Reassessment based only on AIR/CIB information, without verifying the complete bank record before issuing notice under section 148, was not sustained because mere third-party data did not justify reopening without proper examination of the material. The cash deposit addition was also deleted because the bank account had been opened on 29.12.2012, so deposits in that account could not be attributed to the assessment year in question. As the authorities failed to establish the relevant jurisdictional fact, both the reopening and the addition failed.

---

---

Issues: (i) Whether the reassessment initiated on the basis of AIR/CIB information without verification of the complete bank record was valid; (ii) Whether the addition of cash deposits of Rs.35,79,610 was sustainable for the assessment year concerned.

Issue (i): Whether the reassessment initiated on the basis of AIR/CIB information without verification of the complete bank record was valid.

Analysis: The reassessment was founded only on information received through AIR/CIB, while the complete bank statement was not available with the Assessing Officer when notice under section 148 was issued. The record showed that the bank account was opened on 29.12.2012, and that fact had not been examined before forming the belief that income had escaped assessment. Mere receipt of information could set the machinery in motion, but a proper examination of the material with the return was required before reopening.

Conclusion: The reassessment initiation was not sustained.

Issue (ii): Whether the addition of cash deposits of Rs.35,79,610 was sustainable for the assessment year concerned.

Analysis: Since the bank account itself was opened on 29.12.2012, deposits made in that account could not relate to the assessment year in question. The authorities below had not verified this jurisdictional fact, and the addition rested on an incorrect assumption as to the relevant year of deposit. In these circumstances, the cash deposit addition could not be retained.

Conclusion: The addition of Rs.35,79,610 was deleted.

Final Conclusion: The assessee succeeded on both the reopening challenge and the merits of the addition, resulting in deletion of the impugned income addition.

Ratio Decidendi: Reassessment cannot be sustained on unverified third-party information alone, and an addition based on bank deposits fails where the basic jurisdictional fact as to the relevant accounting year is not established.

---