https://www.taxtmi.com/caselaws?id=282734 Reopening under s.147 was upheld because the AO had tangible information to form a reason to believe, the assessee's writ challenge had failed before the HC, and the Department was free to initiate reassessment; the challenge to reopening was rejected. On addition of alleged brokerage income and consequential disallowance u/s 35D, the Tribunal held that a disclosure made in a settlement application (later abated) cannot, by itself, justify an addition absent incriminating material establishing actual undisclosed income; applying the principle in Maruti Fabrics to s.245HA abatement, the brokerage addition and related disallowance were deleted. en-us Wed, 17 May 2017 00:00:00 +0530 Thu, 08 Jan 2026 14:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=282734 Reopening under s.147 was upheld because the AO had tangible information to form a reason to believe, the assessee's writ challenge had failed before the HC, and the Department was free to initiate reassessment; the challenge to reopening was rejected. On addition of alleged brokerage income and consequential disallowance u/s 35D, the Tribunal held that a disclosure made in a settlement application (later abated) cannot, by itself, justify an addition absent incriminating material establishing actual undisclosed income; applying the principle in Maruti Fabrics to s.245HA abatement, the brokerage addition and related disallowance were deleted. Case-Laws Income Tax Wed, 17 May 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=282734