https://www.taxtmi.com/caselaws?id=776254 The ITAT JAIPUR held that the reopening of assessment u/s 147 based on third-party information was not justified as the transactions recorded in the impugned excel sheet were admitted by a third party in his individual capacity, not the assessee. The same transactions were also taxed in the hands of another entity, indicating uncertainty about ownership. The AO failed to examine the third party or provide the assessee an opportunity for cross-examination to establish the true ownership. The tribunal found no evidence linking the transactions to the assessee and ruled that the same income cannot be taxed twice. Consequently, the additions confirmed by the CIT(A) were set aside, and the grounds raised by the assessee were allowed, directing deletion of the addition. en-us Fri, 25 Jul 2025 00:00:00 +0530 Thu, 07 Aug 2025 07:04:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776254 The ITAT JAIPUR held that the reopening of assessment u/s 147 based on third-party information was not justified as the transactions recorded in the impugned excel sheet were admitted by a third party in his individual capacity, not the assessee. The same transactions were also taxed in the hands of another entity, indicating uncertainty about ownership. The AO failed to examine the third party or provide the assessee an opportunity for cross-examination to establish the true ownership. The tribunal found no evidence linking the transactions to the assessee and ruled that the same income cannot be taxed twice. Consequently, the additions confirmed by the CIT(A) were set aside, and the grounds raised by the assessee were allowed, directing deletion of the addition. Case-Laws Income Tax Fri, 25 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776254