https://www.taxtmi.com/caselaws?id=770967 Reopening under section 147 was challenged on the ground that the information allegedly arose from search material and should have triggered section 153C. The assessee failed to produce the panchanama and annexures needed to show that the cash payment information of Rs. 34,41,000 came from seized material, while the available departmental record suggested the reopening was based on Investigation Wing information requiring further verification. Because the source of information could not be conclusively determined on the incomplete record, the matter was remanded to the CIT(A) for fresh examination limited to that issue, with liberty to call for relevant records from both sides. en-us Fri, 09 May 2025 00:00:00 +0530 Fri, 15 May 2026 18:42:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=770967 Reopening under section 147 was challenged on the ground that the information allegedly arose from search material and should have triggered section 153C. The assessee failed to produce the panchanama and annexures needed to show that the cash payment information of Rs. 34,41,000 came from seized material, while the available departmental record suggested the reopening was based on Investigation Wing information requiring further verification. Because the source of information could not be conclusively determined on the incomplete record, the matter was remanded to the CIT(A) for fresh examination limited to that issue, with liberty to call for relevant records from both sides. Case-Laws Income Tax Fri, 09 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=770967