ITAT Says Reopening Cannot Rest on Suspicion or Unsigned Sanction

The reassessment of ₹5.40 crore was triggered by search material concerning a third party, but the Tribunal found no tangible material or live link connecting the assessee to the alleged accommodation entry. 

It further held that the Section 151 sanction, being neither manually nor digitally signed, was invalid, and that the addition could not survive denial of cross-examination of the person whose statement was relied upon.