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    <title>2018 (3) TMI 1858 - ITAT JAIPUR</title>
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    <description>Completed assessments under section 153A can be disturbed only on the basis of incriminating material, and reopening under section 147 requires tangible material showing a bona fide belief of escapement of income; on these facts, the reopening and related additions could not be sustained. Additions based mainly on seized papers and a third-party statement were also deleted because no cross-examination was allowed and no independent corroboration established the assessee&#039;s alleged investments or on-money payments. Where DLC rates for the relevant locality were not fixed, substitution of adjoining-area rates under section 50C was not accepted without a proper DVO valuation, and that issue was remitted for fresh adjudication.</description>
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      <link>https://www.taxtmi.com/caselaws?id=287310</link>
      <description>Completed assessments under section 153A can be disturbed only on the basis of incriminating material, and reopening under section 147 requires tangible material showing a bona fide belief of escapement of income; on these facts, the reopening and related additions could not be sustained. Additions based mainly on seized papers and a third-party statement were also deleted because no cross-examination was allowed and no independent corroboration established the assessee&#039;s alleged investments or on-money payments. Where DLC rates for the relevant locality were not fixed, substitution of adjoining-area rates under section 50C was not accepted without a proper DVO valuation, and that issue was remitted for fresh adjudication.</description>
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