ITAT Hyderabad Quashes U/s 148 Reopening; Third-Party Seized Laptop Data & Non-Compliance with Sec 149(1)(b) Held Fatal

Exel Rubber (P) Ltd Vs DCIT (ITAT Hyderabad) Reopening U/s 148 Quashed – Seized Laptop Data from Third Person & Failure to Satisfy s.149(1)(b) Conditions Held Fatal – ITAT Hyderabad A search u/s 132 in Exel Rubber Group led to seizure of a laptop from the residence of the group’s Accounts Manager containing “Focus 5.5” software with alleged unaccounted cash transactions. Based on this material, the AO issued notice u/s 148 beyond three years and made additions towards undisclosed business receipts, adjustment purchases and unexplained money u/s 69A. CIT(A) partly sustaine...