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    <title>2022 (2) TMI 1526 - ITAT DELHI</title>
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    <description>Reopening of assessment under sections 147/148 was held unsupported where recorded reasons and post-search material relied mainly on uncorroborated third party statements, investigation reports with incorrect particulars, and the assessee was denied effective opportunity for cross examination; reopening was therefore not sustained. Addition under section 68 in respect of share capital, share premium and unsecured loan was deleted because the assessee produced share application forms, confirmations, bank records, audited accounts and MCA data, and coordinate bench precedents establish that solitary third party statements and inspection reports without corroboration are insufficient to uphold such additions.</description>
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      <link>https://www.taxtmi.com/caselaws?id=467163</link>
      <description>Reopening of assessment under sections 147/148 was held unsupported where recorded reasons and post-search material relied mainly on uncorroborated third party statements, investigation reports with incorrect particulars, and the assessee was denied effective opportunity for cross examination; reopening was therefore not sustained. Addition under section 68 in respect of share capital, share premium and unsecured loan was deleted because the assessee produced share application forms, confirmations, bank records, audited accounts and MCA data, and coordinate bench precedents establish that solitary third party statements and inspection reports without corroboration are insufficient to uphold such additions.</description>
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