https://www.taxtmi.com/caselaws?id=465801 Reopening under s.147 was challenged on the ground that no incriminating material was found in search and the only basis was income offered in a petition before the ITSC. The ITAT held that disclosure of additional income before the ITSC, not reflected in the return, constituted specific and definite information giving the AO "reason to believe" escapement of income, and the department was free to invoke s.147; reopening was upheld against the assessee. On merits, the ITAT held that, after reopening, the AO could not sustain an addition merely because income was offered before the ITSC to meet s.245C(1) maintainability, absent incriminating material substantiating undisclosed income; the addition was deleted and the appeal partly allowed. en-us Mon, 27 May 2019 00:00:00 +0530 Fri, 09 Jan 2026 19:03:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465801 Reopening under s.147 was challenged on the ground that no incriminating material was found in search and the only basis was income offered in a petition before the ITSC. The ITAT held that disclosure of additional income before the ITSC, not reflected in the return, constituted specific and definite information giving the AO "reason to believe" escapement of income, and the department was free to invoke s.147; reopening was upheld against the assessee. On merits, the ITAT held that, after reopening, the AO could not sustain an addition merely because income was offered before the ITSC to meet s.245C(1) maintainability, absent incriminating material substantiating undisclosed income; the addition was deleted and the appeal partly allowed. Case-Laws Income Tax Mon, 27 May 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465801