During survey proceedings on third party it was found that assessee had purchased a farm house-. It was further discovered that sale deed was registered at Rs. 1.2 crores at circle rate, but cash component of Rs. 5.41 crores was also paid over and above registered value of Rs. 1.2 crores and that furthermore, assessee had also received payments aggregating to Rs. 3.2 crores during relevant year from person acting on behalf of assessee in said transaction and therefore, even source of payment of Rs. 1.2 crores to seller might not be genuine. Based on said material, Assessing Officer issued notice under section 148 to assessee and thereafter made assessment by estimating cost of acquisition of property and making addition under section 69.  CIT(A) affirmed the order of the AO. On appeal the Tribunal held that  information on basis of which Assessing Officer had initiated proceedings under section 147 was certain and it could be construed to be sufficient and relevant material on basis of which a reasonable person could have formed a belief that income had escaped assessment and, therefore, reassessment proceedings initiated by Assessing Officer were within jurisdiction and valid in eyes of law. However, since addition had been made by Assessing Officer ignoring documentary evidence in form of registered sale deed which is a best evidence for finding actual sale value and in absence of any other material to show that transactions involved cash outside sale consideration mentioned in sale deed and in absence of any corroborative evidence addition was not justified.Further considering fact that entire addition made by Assessing Officer was based on statements of witnesses which had been retracted thereafter and no opportunity of cross examination was granted to assessee by Assessing Officer, Commissioner (Appeals) erred in upholding addition made by Assessing Officer.(AY. 2012-13)