https://www.taxtmi.com/caselaws?id=775163 The ITAT Chandigarh ruled in favor of the assessee company regarding reopening of assessment under section 147. The tribunal held that documents recovered from third parties (Ravi Kapoor, Ajay Prabhakar, Devinder Ghai) during search operations could not be used against the assessee without corroborating evidence. Under section 132(4), documents belong to the person from whose possession they are found. The AO failed to establish proper satisfaction before making additions based on third-party materials including digital data, valuation reports, and money receipts. The tribunal deleted additions totaling Rs. 2.05 crore and Rs. 1.41 crore, noting that no cross-examination was allowed of key witnesses, third parties denied knowledge of transactions, and no direct link was established between seized documents and the assessee company. The CIT(A)'s confirmations were based on presumptions rather than concrete evidence, making the additions unjustified both legally and factually. en-us Thu, 17 Jul 2025 00:00:00 +0530 Sat, 19 Jul 2025 13:36:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775163 The ITAT Chandigarh ruled in favor of the assessee company regarding reopening of assessment under section 147. The tribunal held that documents recovered from third parties (Ravi Kapoor, Ajay Prabhakar, Devinder Ghai) during search operations could not be used against the assessee without corroborating evidence. Under section 132(4), documents belong to the person from whose possession they are found. The AO failed to establish proper satisfaction before making additions based on third-party materials including digital data, valuation reports, and money receipts. The tribunal deleted additions totaling Rs. 2.05 crore and Rs. 1.41 crore, noting that no cross-examination was allowed of key witnesses, third parties denied knowledge of transactions, and no direct link was established between seized documents and the assessee company. The CIT(A)'s confirmations were based on presumptions rather than concrete evidence, making the additions unjustified both legally and factually. Case-Laws Income Tax Thu, 17 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775163