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    <title>2021 (1) TMI 381 - ITAT MUMBAI</title>
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    <description>Non-supply of the recorded reasons before requiring objections vitiated the reassessment, because the assessee was denied the statutory opportunity to contest the reopening. A return filed in response to section 17 notice could not be revised as if it were an original return under section 15, so the rejection of the revised return was upheld. Offshore immovable properties and foreign bank balances were not taxable as the assessee&#039;s wealth without proof that they were personal assets; trust and offshore entity structures could not be ignored merely because of beneficial-owner descriptions. The jewellery addition was not sustained in final form and the matter was remanded for fresh reconciliation of ownership and related family disclosures.</description>
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      <link>https://www.taxtmi.com/caselaws?id=402789</link>
      <description>Non-supply of the recorded reasons before requiring objections vitiated the reassessment, because the assessee was denied the statutory opportunity to contest the reopening. A return filed in response to section 17 notice could not be revised as if it were an original return under section 15, so the rejection of the revised return was upheld. Offshore immovable properties and foreign bank balances were not taxable as the assessee&#039;s wealth without proof that they were personal assets; trust and offshore entity structures could not be ignored merely because of beneficial-owner descriptions. The jewellery addition was not sustained in final form and the matter was remanded for fresh reconciliation of ownership and related family disclosures.</description>
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