https://www.taxtmi.com/caselaws?id=179450 ITAT PUNE - AT held for the assessee: simultaneous search revealed no evidence of fictitious fixed deposits in the assessee's case, AO did not investigate real beneficiaries nor show funds returned to the assessee, and CIT(A) did not specifically direct taxation in the assessee's hands. Tribunal previously allowed the assessee's appeal and dismissed the revenue's appeal. The AO could not issue a notice under s.147 before the earlier order attained finality, and once assessment was framed under s.158BA for undisclosed block-period income, reopening under s.148 was impermissible. Decision for the assessee. en-us Fri, 13 Mar 2015 00:00:00 +0530 Mon, 08 Sep 2025 10:07:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=179450 ITAT PUNE - AT held for the assessee: simultaneous search revealed no evidence of fictitious fixed deposits in the assessee's case, AO did not investigate real beneficiaries nor show funds returned to the assessee, and CIT(A) did not specifically direct taxation in the assessee's hands. Tribunal previously allowed the assessee's appeal and dismissed the revenue's appeal. The AO could not issue a notice under s.147 before the earlier order attained finality, and once assessment was framed under s.158BA for undisclosed block-period income, reopening under s.148 was impermissible. Decision for the assessee. Case-Laws Income Tax Fri, 13 Mar 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=179450