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ITAT upheld the validity of reassessment proceedings initiated under s.147 by notice under s.148, finding no infirmity in reopening based on documents seized from a third party and dismissing the challenge that proceedings should have been under ss.153A/153C. However, ITAT found the substantive additions for alleged cash receipts unsustainable: seized papers did not bear the assessee's name, no corroborative evidence linked the entries to the assessee, and the disputed Rs.5,00,000 was shown returned to a related group company with bank records and no proof of cash receipt by the assessee. AO was directed to delete the additions; respective grounds of appeal were allowed.
ITAT upheld the validity of reassessment proceedings initiated under s.147 by notice under s.148, finding no infirmity in reopening based on documents seized from a third party and dismissing the challenge that proceedings should have been under ss.153A/153C. However, ITAT found the substantive additions for alleged cash receipts unsustainable: seized papers did not bear the assessee's name, no corroborative evidence linked the entries to the assessee, and the disputed Rs.5,00,000 was shown returned to a related group company with bank records and no proof of cash receipt by the assessee. AO was directed to delete the additions; respective grounds of appeal were allowed.
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