Reopening of assessment initiated on basis of a third party...

Reopening of assessment initiated on basis of a third party search was invalid because the assessing officer issued a notice under the general reassessment provision instead of the provision applicable to material seized in a third party search; accordingly the reassessment notice was quashed and the assessee's ground on that point allowed. The appellate authority's deletion of the addition under unexplained cash loan/interest was noted. Objection that the assessment order was cryptic or passed hastily was rejected: delay by the assessee in filing return and seeking reasons, and limitation pressures, meant the gap before final order did not invalidate the assessment process.

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