https://www.taxtmi.com/caselaws?id=791108 Reassessment under section 148 based on search material from a third party was not barred merely because section 153A read with section 153C could also have applied, where the Assessing Officer formed independent satisfaction on seized documents and statements. However, reopening for assessment year 2009-10 beyond four years was invalid because the recorded reasons did not identify any specific failure by the assessee to disclose fully and truly all material facts. Additions based on loose sheets and search-related statements were also deleted, as the material contained contradictions, the retractions were not rebutted, and no independent corroborative evidence established cash payment, receipt, or trail. en-us Tue, 28 Apr 2026 00:00:00 +0530 Wed, 06 May 2026 08:32:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791108 Reassessment under section 148 based on search material from a third party was not barred merely because section 153A read with section 153C could also have applied, where the Assessing Officer formed independent satisfaction on seized documents and statements. However, reopening for assessment year 2009-10 beyond four years was invalid because the recorded reasons did not identify any specific failure by the assessee to disclose fully and truly all material facts. Additions based on loose sheets and search-related statements were also deleted, as the material contained contradictions, the retractions were not rebutted, and no independent corroborative evidence established cash payment, receipt, or trail. Case-Laws Income Tax Tue, 28 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791108