https://www.taxtmi.com/caselaws?id=780110 ITAT DELHI - AT upheld reopening under s.147 based on documents seized from a third party, finding the AO's use of s.147 instead of s.153C/s.153A not bad in law. However, additions treated as cash receipts were deleted: seized papers did not name the taxpayer and no corroborative evidence linked entries to the taxpayer; a Rs.5 lakh item was shown returned to a group company with bank proof and no evidence of cash receipt back. Reopening sustained; income additions set aside and related appeals allowed. en-us Tue, 14 Oct 2025 00:00:00 +0530 Sat, 18 Oct 2025 09:08:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780110 ITAT DELHI - AT upheld reopening under s.147 based on documents seized from a third party, finding the AO's use of s.147 instead of s.153C/s.153A not bad in law. However, additions treated as cash receipts were deleted: seized papers did not name the taxpayer and no corroborative evidence linked entries to the taxpayer; a Rs.5 lakh item was shown returned to a group company with bank proof and no evidence of cash receipt back. Reopening sustained; income additions set aside and related appeals allowed. Case-Laws Income Tax Tue, 14 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780110