#reassessment under Section 147

ITAT Mumbai rules that issuing two reassessment orders under Section 147 for the same transaction in a single assessment year is legally impermissible. The second order renders the first infructuous, setting a precedent against procedural duplication in tax reassessment proceedings.

The ITAT Lucknow deleted a Rs. 6.02 lakh addition under Section 68, ruling that tax authorities cannot treat cash credits as unexplained income merely because the creditor’s income tax returns or financial statements were not submitted. The burden shifts to the department to conduct a proactive inquiry - not just demand impossible documentation from the assessee - reinforcing that conjecture has no place in reassessment proceedings.