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    <title>2025 (2) TMI 1411 - ITAT AHMEDABAD</title>
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    <description>Reopening of assessment may be valid even when material originates from a third party search if the assessing officer independently applies mind to seized information and forms a reason to believe that income has escaped assessment; in such cases reassessment under general provisions is not excluded by search specific provisions, and the reassessment was sustained here. Separately, additions based solely on loose sheets or unverified third party notations lack necessary independent corroboration and cannot support an addition under unexplained receipts; the appellate authority disallowed the addition for want of nexus and corroborative evidence, and the revenue appeal on that point was dismissed.</description>
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      <description>Reopening of assessment may be valid even when material originates from a third party search if the assessing officer independently applies mind to seized information and forms a reason to believe that income has escaped assessment; in such cases reassessment under general provisions is not excluded by search specific provisions, and the reassessment was sustained here. Separately, additions based solely on loose sheets or unverified third party notations lack necessary independent corroboration and cannot support an addition under unexplained receipts; the appellate authority disallowed the addition for want of nexus and corroborative evidence, and the revenue appeal on that point was dismissed.</description>
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