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    <title>2006 (9) TMI 234 - ITAT JODHPUR</title>
    <link>https://www.taxtmi.com/caselaws?id=68631</link>
    <description>Reassessment under section 147 was not sustainable where the income relied on for reopening was already reflected in search material covered by block assessment proceedings under Chapter XIV-B. The recorded reasons concerned items such as bank deposits, rental income, expenses and job income, but these were already part of the search-based material, so the special block assessment scheme applied and section 147 could not be used for the same income. The reopening was also vitiated because the Assessing Officer did not dispose of the assessee&#039;s objections by a speaking order before completing the reassessment. On that basis, the notice under section 148 and the consequential assessment were treated as invalid.</description>
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    <pubDate>Fri, 22 Sep 2006 00:00:00 +0530</pubDate>
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      <title>2006 (9) TMI 234 - ITAT JODHPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=68631</link>
      <description>Reassessment under section 147 was not sustainable where the income relied on for reopening was already reflected in search material covered by block assessment proceedings under Chapter XIV-B. The recorded reasons concerned items such as bank deposits, rental income, expenses and job income, but these were already part of the search-based material, so the special block assessment scheme applied and section 147 could not be used for the same income. The reopening was also vitiated because the Assessing Officer did not dispose of the assessee&#039;s objections by a speaking order before completing the reassessment. On that basis, the notice under section 148 and the consequential assessment were treated as invalid.</description>
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      <pubDate>Fri, 22 Sep 2006 00:00:00 +0530</pubDate>
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