Section 271AAC of the Income Tax Act

The department cannot improve upon the Assessing Officer's case by changing the basis of additions without issuing a show cause notice to the assessee.

Additions to income cannot be made based solely on statements or confessions recorded at the time of a search, without corroborating evidence. Such confessions lack evidentiary value if not supported by other proof.

The Commissioner (CIT) cannot direct the Assessing Officer (AO) to initiate penalty proceedings under Section 271(1)(c) using revisional powers under Section 263 if the AO did not initiate them in the original assessment order. The CIT's revisional power under Section 263 cannot be used to create a non-existent proceeding.

Additions to income cannot be made solely on the basis of uncorroborated notes found on loose sheets or papers, especially if they are undated and lack any identifying names.

Cash deposits made post-demonetization out of cash sales, when supported by stock availability and previous year's sales patterns, cannot be treated as undisclosed income under Section 68.