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    <title>2017 (7) TMI 1041 - ITAT DELHI</title>
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    <description>The Tribunal invalidated the reassessment proceedings under Section 148 of the Income Tax Act, 1961, due to the Assessing Officer&#039;s failure to form a prima facie opinion before reopening the assessment. The additions based on accommodation entries and unsecured loans were upheld, citing lack of evidence on genuineness. The rejection of books of account and application of gross profit rate were affirmed. The Tribunal dismissed the allegation of the firm not engaging in actual business, noting substantial inventory. The addition without allowing cross-examination was deemed a violation of natural justice. The order passed without hearing the assessee was considered a breach of principles of natural justice.</description>
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      <link>https://www.taxtmi.com/caselaws?id=345929</link>
      <description>The Tribunal invalidated the reassessment proceedings under Section 148 of the Income Tax Act, 1961, due to the Assessing Officer&#039;s failure to form a prima facie opinion before reopening the assessment. The additions based on accommodation entries and unsecured loans were upheld, citing lack of evidence on genuineness. The rejection of books of account and application of gross profit rate were affirmed. The Tribunal dismissed the allegation of the firm not engaging in actual business, noting substantial inventory. The addition without allowing cross-examination was deemed a violation of natural justice. The order passed without hearing the assessee was considered a breach of principles of natural justice.</description>
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