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    <title>2012 (7) TMI 36 - ITAT AGRA</title>
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    <description>Reassessment was sustained because the return had only been processed under section 143(1)(a), and the Assessing Officer had recorded reasons based on Investigation Wing information indicating possible escapement of income. In the absence of a completed scrutiny assessment, the objection based on change of opinion failed, and the jurisdictional challenge to section 148 was rejected. On merits, the alleged gift was not proved genuine: the donor was not produced, summons were not complied with, and the surrounding circumstances pointed to an accommodation entry. The assessee failed to discharge the burden of proof, so the additions for unexplained income and related commission were upheld.</description>
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    <pubDate>Tue, 15 Nov 2011 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=214461</link>
      <description>Reassessment was sustained because the return had only been processed under section 143(1)(a), and the Assessing Officer had recorded reasons based on Investigation Wing information indicating possible escapement of income. In the absence of a completed scrutiny assessment, the objection based on change of opinion failed, and the jurisdictional challenge to section 148 was rejected. On merits, the alleged gift was not proved genuine: the donor was not produced, summons were not complied with, and the surrounding circumstances pointed to an accommodation entry. The assessee failed to discharge the burden of proof, so the additions for unexplained income and related commission were upheld.</description>
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      <pubDate>Tue, 15 Nov 2011 00:00:00 +0530</pubDate>
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