Reopening of assessment without fresh material is unsustainable

PCIT Vs Vinita Chaurasia (Delhi High Court) Delhi High Court held that addition on the basis of single seized document is unsustainable as no fresh material was taken into account by the AO for reopening the assessment under Section 147 of the Act. Facts- Present appeal has been filed by Revenue challenging the order passed by ITAT. Revenue contended that ITAT erred in deleting the addition of Rs.34,06,11,102/- without analysing and considering the contents and the words of the seized document, identified in the appeal (‘Seized Document’). He states that as per the said Seized Document the...