https://www.taxtmi.com/caselaws?id=779171 Reopening under section 147 was held unsustainable because the Revenue relied on the same material already examined in the earlier assessment, including unsecured loans and confirmations considered during search-related and section 153A proceedings. No fresh tangible material was shown to justify issuance of notice under section 148, and the first proviso to section 147 barred reassessment on the existing record. The reassessment notice and proceedings were quashed, and the challenge succeeded in favour of the assessee. en-us Mon, 20 Jan 2025 00:00:00 +0530 Tue, 30 Sep 2025 08:30:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779171 Reopening under section 147 was held unsustainable because the Revenue relied on the same material already examined in the earlier assessment, including unsecured loans and confirmations considered during search-related and section 153A proceedings. No fresh tangible material was shown to justify issuance of notice under section 148, and the first proviso to section 147 barred reassessment on the existing record. The reassessment notice and proceedings were quashed, and the challenge succeeded in favour of the assessee. Case-Laws Income Tax Mon, 20 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779171