Tribunal held that reassessment notice can be issued u/s 147 in relation to search and seizure

Amit Mangilal Jain Vs ACIT (ITAT Mumbai) Conclusion: Notice could be issued under section 148 in relation to search and seizure as assessee was one of the investor/partner along with the others to acquire the land for TDR generation which could not be disputed and was admitted in the post search statement by the director and the assessee was provided the benefit of cross examination of the director to test check the authenticity of the transactions. Held: Assessee contended that CIT(A) had erred in confirming the action of AO of re-opening the assessment by issuing notice u/s. 147 which was me...