https://www.taxtmi.com/caselaws?id=399387 The Tribunal found the reassessment proceedings under Section 147 invalid as they were based on a document seized from a third party, ruling that Section 153C should have been applied instead. The addition of Rs. 56,27,160/- based on a seized hard disk was deemed unjustified due to lack of corroborative evidence, with the Tribunal emphasizing the need for independent verification. The Assessing Officer's failure to substantiate the hard disk contents with independent evidence rendered the addition invalid. Consequently, the appeal was allowed, and the addition was deleted, highlighting the importance of corroborative evidence in such cases. en-us Wed, 07 Oct 2020 00:00:00 +0530 Fri, 09 Oct 2020 11:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=399387 The Tribunal found the reassessment proceedings under Section 147 invalid as they were based on a document seized from a third party, ruling that Section 153C should have been applied instead. The addition of Rs. 56,27,160/- based on a seized hard disk was deemed unjustified due to lack of corroborative evidence, with the Tribunal emphasizing the need for independent verification. The Assessing Officer's failure to substantiate the hard disk contents with independent evidence rendered the addition invalid. Consequently, the appeal was allowed, and the addition was deleted, highlighting the importance of corroborative evidence in such cases. Case-Laws Income Tax Wed, 07 Oct 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=399387