#ITAT Surat judgment

ITAT Surat holds that reassessment proceedings under Section 147 of the Income Tax Act beyond four years from the end of the assessment year are invalid unless new tangible material justifying escapement of income is discovered. The ruling quashes reassessment orders for AY 2011-12 and 2014-15, reinforcing the limitation period for tax authorities and protecting assessees from arbitrary reopening of cases.

ITAT Surat holds that cash withdrawals from disclosed bank accounts cannot be treated as unexplained money under Section 69A of the Income Tax Act unless there is evidence linking such withdrawals to undisclosed income. The ruling underscores that mere cash withdrawals, without proof of unaccounted sources, do not justify tax additions, reinforcing the need for concrete evidence in best judgment assessments.