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The issue pertains to the validity of reopening the assessment u/s 147, where an addition was made based on an excel sheet found in a search on an employee of the Maverick Group. The assessee had filed objections against the reasons recorded, which were rejected by the Assessing Officer (AO) in a summary manner. The assessment was completed u/s 143(3) read with Section 147 by adding the said sum, alleging that the assessee had paid interest in cash out of an undisclosed source of income. Initially, a notice u/s 133(6) was issued, alleging that the amount appearing as 'adjustment interest' was interest received, and the assessee was asked to disclose the same in the return of income. However, the assessee explained that the interest was paid by them, not received, and confirmations were submitted during proceedings u/s 153A. The AO changed the stance, alleging that the 'Adjustment' column amount was interest paid by the assessee out of undisclosed sources and not recorded in the books. During the Maverick group's assessment, it was observed that the excel sheet was received from a finance broker working for multiple parties, and the broker was asking for additional interest not given. Relying on the ITAT Jaipur decision in M/s. Maverick Share Brokers Private Limited, it was found that.
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