Section 147 Reopening: Seized Document Needs Corroborative Evidence for Unaccounted Income Assessment. Further Investigation Required.

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....Reopening of assessment u/s 147 - Unaccounted income - As seized document is a piece of evidence which play a vital role to determine the income of the assessee. But such document cannot give absolute power to the authorities below to work out undisclosed income of the assessee without bringing corroborative evidences. The seized document give the information to the AO to dig out the facts in more detail that too in a particular direction. The seized documents must be supported based on other materials indicating that cash received by the assessee was either available or it was utilized in some other manner. - AT....