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ITAT Delhi on 31st jan; 2019 held that CIT(A) could not enhance income of assessee on altogether ‘new Source’. before submitting your written submission kindly read carefully the notes and read case laws mentioned.
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Unless corroborative evidence is found during course of survey, search & seizure, addition cannot be made merely on statement recorded.
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Approval / sanction by merely writing “Approved” to reopen the case u/s 147 is not sustainable