https://www.taxtmi.com/caselaws?id=784491 Reopening under s.147/s.148 pursuant to a search was upheld, as issuance of notice does not require incriminating material in the assessee's possession; existence and sufficiency of material is to be examined in reassessment proceedings, and the regime was treated as analogous to pre-1.4.2021 search assessments. The challenge to jurisdictional validity was dismissed. Use of third-party material gathered behind the assessee's back without confrontation and without opportunity of cross-examination violated ss.142(2) and 142(3), rendering additions based on such material unsustainable. Consequently, the estimated addition for alleged bogus purchases solely based on a tax authority report was deleted. Addition under s.69D (and consequential s.69C) based on unreliable loose papers and presumptions, without corroborative enquiry, was rightly deleted. en-us Fri, 02 Jan 2026 00:00:00 +0530 Tue, 06 Jan 2026 08:48:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784491 Reopening under s.147/s.148 pursuant to a search was upheld, as issuance of notice does not require incriminating material in the assessee's possession; existence and sufficiency of material is to be examined in reassessment proceedings, and the regime was treated as analogous to pre-1.4.2021 search assessments. The challenge to jurisdictional validity was dismissed. Use of third-party material gathered behind the assessee's back without confrontation and without opportunity of cross-examination violated ss.142(2) and 142(3), rendering additions based on such material unsustainable. Consequently, the estimated addition for alleged bogus purchases solely based on a tax authority report was deleted. Addition under s.69D (and consequential s.69C) based on unreliable loose papers and presumptions, without corroborative enquiry, was rightly deleted. Case-Laws Income Tax Fri, 02 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784491