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    <title>2022 (5) TMI 1328 - ITAT JABALPUR</title>
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    <description>Reopening under section 148 was upheld because the challenge to approval under section 151 was vague, unsupported by record, and did not displace the presumption that official acts are regularly performed. On the income issue, the Tribunal treated the cash deposits and bank transactions as linked to an accommodation-entry style cheque-issue business, but held that the entire gross deposits could not automatically be taxed as the assessee&#039;s income. In the absence of reliable evidence of the claimed business model, the additions were confined to the excess of credits over debits in one account and the unexplained cash deposit in the other, reflecting a limited estimation of real income on the available material.</description>
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      <description>Reopening under section 148 was upheld because the challenge to approval under section 151 was vague, unsupported by record, and did not displace the presumption that official acts are regularly performed. On the income issue, the Tribunal treated the cash deposits and bank transactions as linked to an accommodation-entry style cheque-issue business, but held that the entire gross deposits could not automatically be taxed as the assessee&#039;s income. In the absence of reliable evidence of the claimed business model, the additions were confined to the excess of credits over debits in one account and the unexplained cash deposit in the other, reflecting a limited estimation of real income on the available material.</description>
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