Reopening U/s 148 Quashed for Want of Satisfaction on Third-Party Seized Material – Reassessment Void: ITAT Hyderabad

EXEL Rubber Private Ltd Vs DCIT (ITAT Hyderabad) Reopening u/s 148 Quashed – Material Seized from Third Person Requires Satisfaction u/s 148 Exp.(2)(iii)/(iv) – Entire Reassessment Held Void – ITAT Hyderabad Pursuant to search u/s 132 in Exel Rubber Group, the AO reopened assessments based on alleged unaccounted cash transactions recorded in “FOCUS 5.5” software found in the laptop of the group’s Senior Accounts Manager during a separate search. Additions were made towards adjustment purchase transactions relying primarily on seized third-party material and statements. Before ITAT,...