https://www.taxtmi.com/caselaws?id=466722 Assessment addition of Rs. 45,00,000 was deleted because ledger evidence established an opening balance carried forward from earlier years and Revenue failed to rebut those documents, so the addition could not be sustained for the assessment year. Separately, notices issued under the general reopening provision based solely on documents seized from a third party were held invalid because seized third-party materials must be transferred and proceedings initiated under the procedural mechanism applicable to third-party seizures; thus reliance on the general reopening route was jurisdictionally improper and the notice was quashed. en-us Wed, 07 May 2025 00:00:00 +0530 Mon, 16 Feb 2026 15:06:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466722 Assessment addition of Rs. 45,00,000 was deleted because ledger evidence established an opening balance carried forward from earlier years and Revenue failed to rebut those documents, so the addition could not be sustained for the assessment year. Separately, notices issued under the general reopening provision based solely on documents seized from a third party were held invalid because seized third-party materials must be transferred and proceedings initiated under the procedural mechanism applicable to third-party seizures; thus reliance on the general reopening route was jurisdictionally improper and the notice was quashed. Case-Laws Income Tax Wed, 07 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466722