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    <title>1985 (7) TMI 12 - DELHI High Court</title>
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    <description>The Tribunal upheld the validity of proceedings under section 147(a) of the Income-tax Act, finding that reasons for reopening the assessment were recorded based on uchanti books. The Commissioner of Income-tax (Appeals) confirmed this validity, dismissing the contention of no recorded reasons. The Court determined that no new source of income was created, as transactions were within the existing business scope. The Commissioner&#039;s decision was based on existing evidence and did not constitute enhancement. The alleged double taxation issue lacked factual basis and the application was dismissed, with parties bearing their own costs.</description>
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    <pubDate>Mon, 15 Jul 1985 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=26154</link>
      <description>The Tribunal upheld the validity of proceedings under section 147(a) of the Income-tax Act, finding that reasons for reopening the assessment were recorded based on uchanti books. The Commissioner of Income-tax (Appeals) confirmed this validity, dismissing the contention of no recorded reasons. The Court determined that no new source of income was created, as transactions were within the existing business scope. The Commissioner&#039;s decision was based on existing evidence and did not constitute enhancement. The alleged double taxation issue lacked factual basis and the application was dismissed, with parties bearing their own costs.</description>
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      <pubDate>Mon, 15 Jul 1985 00:00:00 +0530</pubDate>
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