Reopening of assessment u/s 147 was based on reasons to believe the difference between total cash sales...

Reopening of assessment u/s 147 was based on reasons to believe the difference between total cash sales and cash sales reflected in books. Held: Reopening was made only based on discrepancy noticed from impounded material relevant to the year under consideration. AO during regular assessment verified the same impounded material and issued notice u/s 142(1) for explanation regarding transactions in impounded documents. AO also called for further details regarding impounded material found during survey relevant to the assessment year, explaining total difference in day-wise amount. Hence, during regular assessment, the issue of totaling difference in impounded material was considered. Therefore, it cannot be said that the impugned notice was ..... .....

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