https://www.taxtmi.com/caselaws?id=789895 Reassessment under sections 147 and 148 was upheld because, in the post-search framework applied here, the absence of incriminating material at the notice stage did not invalidate reopening; the material could be tested during reassessment proceedings. Additions under sections 68 and 69C were deleted because the investments had been disclosed and accepted in earlier scrutiny, sale proceeds moved through banking channels, and the Revenue relied mainly on third-party statements and a seized document without allowing cross-examination or producing independent corroboration. An untested or retracted statement, by itself, could not sustain the additions. en-us Thu, 02 Apr 2026 00:00:00 +0530 Thu, 16 Apr 2026 08:34:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789895 Reassessment under sections 147 and 148 was upheld because, in the post-search framework applied here, the absence of incriminating material at the notice stage did not invalidate reopening; the material could be tested during reassessment proceedings. Additions under sections 68 and 69C were deleted because the investments had been disclosed and accepted in earlier scrutiny, sale proceeds moved through banking channels, and the Revenue relied mainly on third-party statements and a seized document without allowing cross-examination or producing independent corroboration. An untested or retracted statement, by itself, could not sustain the additions. Case-Laws Income Tax Thu, 02 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789895