https://www.taxtmi.com/caselaws?id=456773 ITAT Chandigarh held that reassessment proceedings u/s 147 were invalid where AO relied solely on third-party information without independent verification or application of mind. The court found AO failed to examine material facts, wrongly stated facts to obtain PCIT approval, and violated natural justice principles by denying cross-examination of the person whose statement formed basis of additions. Since no incriminating material existed and original assessment had considered the disputed transactions, reopening after four years was unsustainable. Addition u/s 68 was deleted as AO relied on secondary material without proper enquiry despite assessee discharging initial onus. en-us Fri, 15 Sep 2023 00:00:00 +0530 Tue, 13 Aug 2024 19:58:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=456773 ITAT Chandigarh held that reassessment proceedings u/s 147 were invalid where AO relied solely on third-party information without independent verification or application of mind. The court found AO failed to examine material facts, wrongly stated facts to obtain PCIT approval, and violated natural justice principles by denying cross-examination of the person whose statement formed basis of additions. Since no incriminating material existed and original assessment had considered the disputed transactions, reopening after four years was unsustainable. Addition u/s 68 was deleted as AO relied on secondary material without proper enquiry despite assessee discharging initial onus. Case-Laws Income Tax Fri, 15 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=456773