Reassessment Quashed as AO Relied on Borrowed Satisfaction Without Independent Analysis

Advertisement Prakash Chand Kothari Vs DCIT (ITAT Jaipur) The Income Tax Appellate Tribunal (ITAT), Jaipur, disposed of cross appeals filed by the assessee and the Revenue relating to Assessment Year 2011-12. The principal issues concerned the validity of reassessment proceedings initiated under Section 147 of the Income-tax Act, 1961, and additions made on account of alleged cash loans and interest based on material seized during a search conducted on a third party, the Ramesh Manihar Group. The assessee’s original return was accepted under Section 143(3). Subsequently, following a searc...