https://www.taxtmi.com/caselaws?id=784490 For a search conducted on or after 01.04.2021, the Tribunal held that issuance of notice under s.148 is not contingent on discovery of incriminating material during search; under the new scheme the AO is obliged to reopen the statutorily covered assessment years, and the existence of material warranting additions is to be examined in s.147 proceedings, not at the notice stage. The challenge to reopening was rejected. On addition relating to alleged non-genuine sale of investment, the Tribunal held the AO relied on statements/material not confronted to the assessee, ignored that fund-raising and private equity investments had been scrutinized and accepted in an earlier year, and adopted an inconsistent approach by partly accepting and partly rejecting the same transaction. The addition was directed to be deleted, and the appeal was allowed. 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=784490 For a search conducted on or after 01.04.2021, the Tribunal held that issuance of notice under s.148 is not contingent on discovery of incriminating material during search; under the new scheme the AO is obliged to reopen the statutorily covered assessment years, and the existence of material warranting additions is to be examined in s.147 proceedings, not at the notice stage. The challenge to reopening was rejected. On addition relating to alleged non-genuine sale of investment, the Tribunal held the AO relied on statements/material not confronted to the assessee, ignored that fund-raising and private equity investments had been scrutinized and accepted in an earlier year, and adopted an inconsistent approach by partly accepting and partly rejecting the same transaction. The addition was directed to be deleted, and the appeal was allowed. Case-Laws Income Tax Fri, 02 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784490