https://www.taxtmi.com/caselaws?id=788029 Reopening under section 147 was justified where seized documents, a statement recorded during GST search proceedings and communications from CGST/Central Excise indicated undisclosed manufacture, and retraction lacked evidence of coercion; consequence: reassessment and notice under section 148 upheld. The assessing officer's adoption of seized valuation and application of a conservative industry-based job work rate (4%) to compute unexplained job-work receipts was treated as a reasonable estimation in absence of positive books-rejection or specific rebuttal; consequence: addition sustained. Overall effect: assessments/reassessments confirmed and appeals dismissed on these grounds. en-us Mon, 23 Feb 2026 00:00:00 +0530 Mon, 16 Mar 2026 08:42:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788029 Reopening under section 147 was justified where seized documents, a statement recorded during GST search proceedings and communications from CGST/Central Excise indicated undisclosed manufacture, and retraction lacked evidence of coercion; consequence: reassessment and notice under section 148 upheld. The assessing officer's adoption of seized valuation and application of a conservative industry-based job work rate (4%) to compute unexplained job-work receipts was treated as a reasonable estimation in absence of positive books-rejection or specific rebuttal; consequence: addition sustained. Overall effect: assessments/reassessments confirmed and appeals dismissed on these grounds. Case-Laws Income Tax Mon, 23 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788029