https://www.taxtmi.com/caselaws?id=782631 ITAT Chandigarh-AT held that, consequent to a search u/s 132, the AO was bound to proceed under the special scheme of ss. 147/148 (read with Expl. 2(iv) and s. 148B) and obtain valid prior approval; continuation and completion of scrutiny u/s 143(3), without such notice and with mechanical, non-speaking approval u/s 153D, rendered the assessment order without jurisdiction and invalid. On merits, the Tribunal upheld addition of the alleged "opening balance" as unexplained, sustained addition of 20% of unmatched entries in seized material, and, while affirming rejection of books u/s 145(3), directed estimation of gross profit at 14%, reducing the rate applied by the AO and marginally modifying that sustained by CIT(A). en-us Tue, 04 Nov 2025 00:00:00 +0530 Tue, 02 Dec 2025 08:35:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782631 ITAT Chandigarh-AT held that, consequent to a search u/s 132, the AO was bound to proceed under the special scheme of ss. 147/148 (read with Expl. 2(iv) and s. 148B) and obtain valid prior approval; continuation and completion of scrutiny u/s 143(3), without such notice and with mechanical, non-speaking approval u/s 153D, rendered the assessment order without jurisdiction and invalid. On merits, the Tribunal upheld addition of the alleged "opening balance" as unexplained, sustained addition of 20% of unmatched entries in seized material, and, while affirming rejection of books u/s 145(3), directed estimation of gross profit at 14%, reducing the rate applied by the AO and marginally modifying that sustained by CIT(A). Case-Laws Income Tax Tue, 04 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782631