Addition Based on Third-Party Software Data Invalid Without Cross-Examination: ITAT Mumbai

S. Sagar Enterprise Vs DCIT (ITAT Mumbai) The appeal before the ITAT Mumbai arose from reassessment proceedings conducted under Sections 147 and 148 of the Income Tax Act for Assessment Year 2019–20. The assessee, engaged in the business of trading diamonds, had originally filed its return declaring total income of ₹1.32 crore. The case was reopened through a notice dated 27.02.2023, and in response, the assessee reiterated the same income. During reassessment, the Assessing Officer (AO) issued notices under Section 142(1) and completed the assessment on 08.02.2024 by making an addition of...