https://www.taxtmi.com/caselaws?id=753865 Gujarat HC dismissed petition challenging reopening of assessment u/s 147. Petitioner contested satisfaction note for reopening, claiming incriminating material lacked direct correlation with escaped income for relevant assessment year. Court held that since petitioner responded to notice u/s 142(1) on merits and allowed AO to pass assessment order, dispute involved factual questions regarding veracity of seized materials rather than pure legal issues. AO considered petitioner's detailed reply and documentary evidence before making additions based on unaccounted cash transactions found in search. Court directed petitioner to pursue appeal before CIT(A) as alternative remedy. en-us Thu, 09 May 2024 00:00:00 +0530 Tue, 11 Jun 2024 19:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=753865 Gujarat HC dismissed petition challenging reopening of assessment u/s 147. Petitioner contested satisfaction note for reopening, claiming incriminating material lacked direct correlation with escaped income for relevant assessment year. Court held that since petitioner responded to notice u/s 142(1) on merits and allowed AO to pass assessment order, dispute involved factual questions regarding veracity of seized materials rather than pure legal issues. AO considered petitioner's detailed reply and documentary evidence before making additions based on unaccounted cash transactions found in search. Court directed petitioner to pursue appeal before CIT(A) as alternative remedy. Case-Laws Income Tax Thu, 09 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=753865