https://www.taxtmi.com/caselaws?id=412354 Reopening under section 147 was found unsustainable where the reasons rested only on seized material from a group concern and no document belonging to the assessee was found. The record showed no independent evidence, statement, or enquiry linking the assessee to the alleged cash interest payments or additional land payments, and the reasons for reassessment were identical to those in connected group cases. In these circumstances, inferred reliance on material relating to other assessees could not confer jurisdiction. The reassessment was therefore treated as invalid and void ab initio, leaving the merits of the additions academic. en-us Mon, 13 Sep 2021 00:00:00 +0530 Thu, 16 Sep 2021 09:05:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=412354 Reopening under section 147 was found unsustainable where the reasons rested only on seized material from a group concern and no document belonging to the assessee was found. The record showed no independent evidence, statement, or enquiry linking the assessee to the alleged cash interest payments or additional land payments, and the reasons for reassessment were identical to those in connected group cases. In these circumstances, inferred reliance on material relating to other assessees could not confer jurisdiction. The reassessment was therefore treated as invalid and void ab initio, leaving the merits of the additions academic. Case-Laws Income Tax Mon, 13 Sep 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=412354