A jurisdictional challenge to reassessment under section 147,...

A jurisdictional challenge to reassessment under section 147, raised for the first time in cross-objection on the footing that section 153C should have applied, was not entertained because it required fresh factual inquiry beyond the existing appellate record and no such challenge had been raised before the first appellate authority. The tribunal also upheld best judgment estimation of commission income from accommodation entries, holding that the appellate authority could not replace the Assessing Officer's estimate of 2% with 0.5% without identifying any evidentiary or legal infirmity in the original estimate. The assessee's cross-objections were dismissed and the additions were restored.