https://www.taxtmi.com/caselaws?id=405885 Reopening under section 147 was sustained because the recorded reasons had a live nexus with the belief that income had escaped assessment, and a prima facie basis from search material was sufficient at the notice stage. The additions based on unsigned diary jottings and alleged cash payments were deleted because the entries were uncorroborated, lacked clear linkage to the assessee or the relevant years, and were unsupported by independent evidence. The absence of copies of seized material and an opportunity to confront relied-upon statements further undermined the additions. The reassessment challenge failed, but the merits-based additions were not upheld, so the appeals were partly allowed. en-us Mon, 22 Feb 2021 00:00:00 +0530 Thu, 01 Apr 2021 08:44:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=405885 Reopening under section 147 was sustained because the recorded reasons had a live nexus with the belief that income had escaped assessment, and a prima facie basis from search material was sufficient at the notice stage. The additions based on unsigned diary jottings and alleged cash payments were deleted because the entries were uncorroborated, lacked clear linkage to the assessee or the relevant years, and were unsupported by independent evidence. The absence of copies of seized material and an opportunity to confront relied-upon statements further undermined the additions. The reassessment challenge failed, but the merits-based additions were not upheld, so the appeals were partly allowed. Case-Laws Income Tax Mon, 22 Feb 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=405885