In a search on the Sushil Lahoti group, statements indicated accommodation entries; relying on this information (and not on any seized material “belonging to” the assessee), the AO reopened the case of Manju Diamonds Pvt. Ltd. u/s 147 and added ₹75.50 lakh u/s 68 for unsecured loans from four Lahoti-linked companies after 133(6) notices went uncomplied. On appeal the CIT( A)  deleted the additions on  merits, on the ground  that the addition rested solely on Lahoti’s untested statement without supplying the statement or permitting cross-examination and  breach of natural justice and shifted onus under S. 68 once confirmations/PANs/bank statements were filed.  On appeal by the revenue   before the Tribunal  the assessee invoked Rule 27 to contend that the correct route was 153C  and not reassessment proceedings under section 147,   hence re assessment was bad in law . The Tribunal admitted the application under Rule 27 of the ITAT Rules .  The Tribunal held that since no document/material “pertaining to/belonging to” the assessee was found in the Lahoti search, 153C was not attracted and the AO could invoke 147 on external information; therefore, the reassessment was upheld and application under Rule 27 was rejected on merits . As regards the deletion of addition by the CIT( A), on merit the Tribunal held that  as the CIT(A) had deleted the addition outright without a full appraisal vis-à-vis the AO’s enquiries and the assessee’s primary evidence, and because the foundation was largely a third-party statement without cross-examination, the issue on merits was set aside and remanded to the CIT(A) for fresh decision after supplying material and affording effective cross-examination/verification as per law. ( AY. 2017-18 )  ITA No. 2766/MUM/2025, dt .  30-07-2025)