https://www.taxtmi.com/caselaws?id=462221 A reopening after four years requires a demonstrated failure by the assessee to fully and truly disclose material facts, and approval under section 151 must show real application of mind; a mechanical sanction is insufficient. The note also explains that section 69D applies only where an actual hundi borrowing or repayment is proved. Where surrounding documents point to a disputed property transaction, and the Revenue lacks corroboration for a cash loan on hundi, the addition cannot stand. It further notes that cheques or related documents may be treated as collateral security rather than proof of taxable borrowing. en-us Mon, 24 Mar 2025 00:00:00 +0530 Thu, 29 May 2025 11:23:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462221 A reopening after four years requires a demonstrated failure by the assessee to fully and truly disclose material facts, and approval under section 151 must show real application of mind; a mechanical sanction is insufficient. The note also explains that section 69D applies only where an actual hundi borrowing or repayment is proved. Where surrounding documents point to a disputed property transaction, and the Revenue lacks corroboration for a cash loan on hundi, the addition cannot stand. It further notes that cheques or related documents may be treated as collateral security rather than proof of taxable borrowing. Case-Laws Income Tax Mon, 24 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462221