Reopening Assessment Under Section 147 Invalid Without Direct Link or Cross-Examination Opportunity

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....The ITAT held that reopening of assessment u/s 147 based on third-party information recovered from a search at Radha Mohan Totla's associate was invalid as the transactions recorded in the excel sheet found on the pen drive were admitted by Mr. Ajit Singh in his individual capacity, who also paid tax thereon. The assessee's liability could not be fastened as the digital evidence was not in his name, and no direct link or ownership of transactions was established against him. The same transactions were also the subject matter of reassessment proceedings against M/s Unique Dream Builders Pvt Ltd, raising the principle against double taxation of identical income. The AO failed to examine the third party or provide the assessee an opportunity f.........