Dy. CIT v. Murarilal R. Mittal (2021) 214 TTJ 665 / 208 DTR 17 / 63 CCH 436 (TM) (Mum.)(Trib.)

S. 147 : Reassessment-With in four years-Absence of new or tangible material-Undisclosed money disclosed u/s.132 (4)-Cash deposited in the bank-Re assessment was held to be not valid. [S. 132(4), 148]

Dismissing the appeal of the revenue, Tribunal held that the Assessing Officer in the course of original assessment proceedings  enquired about the cash deposits in the savings bank account on the basis of income declared u/s 132(4) of the Act. The information about the deposits in the bank was neither a new fact nor a new tangible material hence  reassessment  is held to be bad in law. (AY. 2011-12)