In the result, both the appeals are dismissed
Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria
iii) That the addition has been made without bringing any adverse material or evidence on record merely on the basis of action under section 132 on some other assessee. (iv) That the addition has been made without any further investigation merely on the basis of presumption. 5.1 From the very beginning, it is clear that the re-assessment proceedings were