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    <title>2021 (6) TMI 266 - ITAT MUMBAI</title>
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    <description>Reassessment was sustained where tangible information from the Investigation Wing provided a live link to alleged escaped income, and the proviso to section 147 was held not to bar reopening of a third party on the basis of material gathered in another case. The approval for notice under section 148 was treated as a conscious exercise of power, and the absence of a request for recorded reasons meant non-supply did not vitiate the proceedings. On merits, the assessee was treated as the effective owner of the property, the seized document was accepted as reliable evidence corroborated by surrounding circumstances and the statutory presumption under section 292C, and the cash component was upheld as unexplained sale consideration in the assessee&#039;s hands.</description>
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      <description>Reassessment was sustained where tangible information from the Investigation Wing provided a live link to alleged escaped income, and the proviso to section 147 was held not to bar reopening of a third party on the basis of material gathered in another case. The approval for notice under section 148 was treated as a conscious exercise of power, and the absence of a request for recorded reasons meant non-supply did not vitiate the proceedings. On merits, the assessee was treated as the effective owner of the property, the seized document was accepted as reliable evidence corroborated by surrounding circumstances and the statutory presumption under section 292C, and the cash component was upheld as unexplained sale consideration in the assessee&#039;s hands.</description>
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