ITAT Jaipur says Cash Advances and Alleged Interest Alone Cannot Justify Extended Reassessment

The ITAT Jaipur quashed reassessment proceedings initiated beyond the ordinary limitation period where the Department relied on seized digital data recording cash advances of ₹62.47 lakh and alleged interest of ₹3.31 lakh. During assessment, the Assessing Officer accepted the assessee's explanation regarding the source of the cash advances and made no addition on that account. The Tribunal held that the seized entries, without further material establishing their undisclosed character, could not support a belief that income exceeding ₹50 lakh had escaped assessment. With only the alleged interest of ₹3.31 lakh remaining as the potential escaped income, the extended limitation provision was unavailable.