https://www.taxtmi.com/caselaws?id=58317 Reassessment under section 147(a) was upheld because a later statement from the creditor's secretary constituted relevant material supporting a reasonable belief of escapement, and the reopening was not treated as a mere change of opinion. The addition for the alleged loan and interest was deleted because the assessee had already produced primary documentary evidence showing the creditor's identity and payment through account payee cheques, while the adverse statement was not tested by cross-examination and no supporting circumstantial evidence rebutted the original record. The ratio is that reopening may rest on subsequent material, but an addition cannot stand where documentary evidence is unrebutted and fair opportunity to challenge adverse material is denied. en-us Thu, 13 Jun 1991 00:00:00 +0530 Sat, 18 Dec 2010 14:10:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=58317 Reassessment under section 147(a) was upheld because a later statement from the creditor's secretary constituted relevant material supporting a reasonable belief of escapement, and the reopening was not treated as a mere change of opinion. The addition for the alleged loan and interest was deleted because the assessee had already produced primary documentary evidence showing the creditor's identity and payment through account payee cheques, while the adverse statement was not tested by cross-examination and no supporting circumstantial evidence rebutted the original record. The ratio is that reopening may rest on subsequent material, but an addition cannot stand where documentary evidence is unrebutted and fair opportunity to challenge adverse material is denied. Case-Laws Income Tax Thu, 13 Jun 1991 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=58317