ITAT quashes time-barred reassessment notice lacking supporting evidence beyond seized cash papers
The ITAT ruled that mere documents reflecting cash advances and calculated interest do not constitute valid grounds to believe income escaped assessment. The tribunal set aside a time-barred reassessment notice due to a lack of relevant corroborative evidence.
Effective Not specified in the update
For professionals: Review pending reassessment notices for similar evidentiary gaps where notices rely solely on seized papers or assumed interest. Prepare challenges by checking whether there is independent corroborative evidence linking seized documents to actual undisclosed income. Advise clients that mere assumptions drawn from isolated financial jottings and time-barred notices fail the foundational requirement for reopening past assessments. · Ensure compliance defenses emphasize the judicial standard demanding robust corroboration before tax authorities can disrupt settled tax years based on primary paper trails.
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