https://www.taxtmi.com/caselaws?id=469945 Reassessment under sections 147 and 148 was treated as invalid where the Assessing Officer relied on the same material already considered in the completed search assessment, because no new tangible material existed and the reopening amounted to a change of opinion. Where the information came from seized material of a third party, the proper course was section 153C, so proceedings under sections 147 and 148 were without jurisdiction. An addition treated as cash loan income under section 69A also failed because it rested only on third-party loose sheets and statements, without corroboration, proof of authorship, or cross-examination. The Revenue's challenge therefore failed on jurisdiction and merits. en-us Tue, 21 Apr 2026 00:00:00 +0530 Thu, 09 Jul 2026 20:20:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469945 Reassessment under sections 147 and 148 was treated as invalid where the Assessing Officer relied on the same material already considered in the completed search assessment, because no new tangible material existed and the reopening amounted to a change of opinion. Where the information came from seized material of a third party, the proper course was section 153C, so proceedings under sections 147 and 148 were without jurisdiction. An addition treated as cash loan income under section 69A also failed because it rested only on third-party loose sheets and statements, without corroboration, proof of authorship, or cross-examination. The Revenue's challenge therefore failed on jurisdiction and merits. Case-Laws Income Tax Tue, 21 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469945