Uncorroborated retracted search statements, third-party tally...

Uncorroborated retracted search statements, third-party tally data and WhatsApp material were found insufficient to sustain alleged commission additions in the individual assessee's case, because there was no cash trail, bank entry or independent documentary proof of receipt; the additions were deleted. Reassessment notices issued beyond three years were held invalid where section 149(1)(b) was not satisfied, as the alleged escapement did not meet the Rs. 50 lakh threshold; the reassessment proceedings were quashed. In the company's case, alleged cash-sales and commission-expenditure issues were remanded for fresh adjudication because factual verification and 65B compliance were required.

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