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    <title>2006 (10) TMI 380 - ITAT BANGALORE</title>
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    <description>Reopening under section 147 was invalid where the recorded reasons rested on a false factual premise and showed no genuine application of mind; the reassessments for the years concerned were therefore bad in law. The seva commission arising from the hereditary right to perform pooja was held to belong to the Hindu undivided family, not the assessee individually, because the income flowed from an inherited family source and there is no estoppel against statute. Additions for tatte kanike, family pooja expenses and travelling expenses, made only by revising earlier estimates without fresh material, were deleted. The balance salary expenditure was allowed in full on the basis of supporting records and prior acceptance.</description>
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      <title>2006 (10) TMI 380 - ITAT BANGALORE</title>
      <link>https://www.taxtmi.com/caselaws?id=151722</link>
      <description>Reopening under section 147 was invalid where the recorded reasons rested on a false factual premise and showed no genuine application of mind; the reassessments for the years concerned were therefore bad in law. The seva commission arising from the hereditary right to perform pooja was held to belong to the Hindu undivided family, not the assessee individually, because the income flowed from an inherited family source and there is no estoppel against statute. Additions for tatte kanike, family pooja expenses and travelling expenses, made only by revising earlier estimates without fresh material, were deleted. The balance salary expenditure was allowed in full on the basis of supporting records and prior acceptance.</description>
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