https://www.taxtmi.com/caselaws?id=465546 ITAT Indore held that reassessment under section 147 was invalid where a survey case should have been taken for compulsory scrutiny under CBDT Instruction No. 5/2017 and no timely notice under section 143(2) was issued; reopening could not be used as a substitute for the missed scrutiny proceeding. It also held that an addition for unexplained expenditure under section 69C could not rest solely on an impounded handwritten mobile note that did not clearly identify the assessee, the parties, the date, or the payment mode and lacked independent corroboration. Both the reassessment and the addition were deleted, granting full relief to the assessee. en-us Fri, 21 Feb 2025 00:00:00 +0530 Mon, 29 Dec 2025 16:13:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465546 ITAT Indore held that reassessment under section 147 was invalid where a survey case should have been taken for compulsory scrutiny under CBDT Instruction No. 5/2017 and no timely notice under section 143(2) was issued; reopening could not be used as a substitute for the missed scrutiny proceeding. It also held that an addition for unexplained expenditure under section 69C could not rest solely on an impounded handwritten mobile note that did not clearly identify the assessee, the parties, the date, or the payment mode and lacked independent corroboration. Both the reassessment and the addition were deleted, granting full relief to the assessee. Case-Laws Income Tax Fri, 21 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465546