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    <title>2017 (7) TMI 660 - ITAT DELHI</title>
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    <description>In reassessment, failure to issue and serve notice under section 143(2) after notice under section 148 was treated as a mandatory jurisdictional defect; section 292BB was held not to cure complete non-issuance of notice, and the reassessment was quashed. The reopening was also invalid because the recorded reasons were based on borrowed satisfaction from Investigation Wing information without independent application of mind or adequate underlying material, so the section 147 jurisdictional requirement of bona fide reasons to believe was not met. For the share application money addition under section 68, the assessee furnished evidence of identity and financial status of the investing companies and the Revenue made no effective rebuttal, so the addition was deleted.</description>
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    <pubDate>Thu, 30 Mar 2017 00:00:00 +0530</pubDate>
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      <title>2017 (7) TMI 660 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=345548</link>
      <description>In reassessment, failure to issue and serve notice under section 143(2) after notice under section 148 was treated as a mandatory jurisdictional defect; section 292BB was held not to cure complete non-issuance of notice, and the reassessment was quashed. The reopening was also invalid because the recorded reasons were based on borrowed satisfaction from Investigation Wing information without independent application of mind or adequate underlying material, so the section 147 jurisdictional requirement of bona fide reasons to believe was not met. For the share application money addition under section 68, the assessee furnished evidence of identity and financial status of the investing companies and the Revenue made no effective rebuttal, so the addition was deleted.</description>
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      <pubDate>Thu, 30 Mar 2017 00:00:00 +0530</pubDate>
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