Tribunal held that the parties have denied the cash loans, not examined the parties, neither original agreement was brought on record neither report of hand writing expert obtained. Reassessment is held to be not valid. Correct course of action could have been action u/s. 153C and not reassessment. Accordingly the addition is deleted. (AY.2010-11)
Adarsh Agrawal v. ITO (2020) 77 ITR 52 (SN) (Delhi)(Trib.)
S. 147 : Reassessment–With in four years-Search and seizure– Alleged cash loans–Parties denying cash loans-Reassessment is held to be nor valid–Correct legal course could have been action u/s. 153C and not reassessment–Addition is deleted. [S. 132, 153A, 153C, 148]