https://www.taxtmi.com/caselaws?id=800590 Post-2021 reassessment remains valid where transaction-specific information supports action under Sections 148A and 148, and retrospective Section 147A governs the meaning of Assessing Officer. For disputed purchases, supplier-related deficiencies and accommodation-bill information do not justify full treatment as unexplained expenditure under Section 69C where invoices, e-way bills, banking and GST records, quantitative details and accepted corresponding sales support the transactions, with no return of funds established. The addition should therefore be confined to estimated embedded profit, assessed at 6% based on gross-profit history. Paragraph 3.1(c) of CBDT Circular No. 5/2024 concerns departmental appeal maintainability and does not require vacatur or fresh assessment. en-us Fri, 25 Sep 2026 00:00:00 +0530 Thu, 08 Oct 2026 08:45:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800590 Post-2021 reassessment remains valid where transaction-specific information supports action under Sections 148A and 148, and retrospective Section 147A governs the meaning of Assessing Officer. For disputed purchases, supplier-related deficiencies and accommodation-bill information do not justify full treatment as unexplained expenditure under Section 69C where invoices, e-way bills, banking and GST records, quantitative details and accepted corresponding sales support the transactions, with no return of funds established. The addition should therefore be confined to estimated embedded profit, assessed at 6% based on gross-profit history. Paragraph 3.1(c) of CBDT Circular No. 5/2024 concerns departmental appeal maintainability and does not require vacatur or fresh assessment. Case-Laws Income Tax Fri, 25 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800590