Reopening under s.147/s.148 for a post-search unabated year was...

Reopening under s.147/s.148 for a post-search unabated year was upheld, as issuance of notice does not require incriminating material found with the assessee and the existence of material warranting additions is to be examined during reassessment proceedings; objections that additions were based on third-party search material were rejected. Additions founded on information gathered behind the assessee's back without confronting the material or allowing cross-examination were held to violate s.142(2)/(3) and were unsustainable. Estimated addition for alleged bogus purchases based solely on a GST report, without independent enquiry despite documentary purchase evidence, was deleted. Additions u/s 69D/69C for alleged cash loans based on unreliable third-party loose papers and conjecture were quashed. - ITAT

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