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    <title>2022 (8) TMI 193 - ITAT PUNE</title>
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    <description>Reassessment challenge for want of a fresh section 143(2) notice after the assessee&#039;s belated request to treat the original return as filed in response to section 148 was rejected, as the request was beyond time and the Assessing Officer could proceed on the notices already issued. The addition for alleged unaccounted cash receipts on land sale was deleted because it was based on third-party loose sheets and a retracted statement that was not tested by cross-examination; the material was vague, not clearly linked to the assessee or the year in issue, and lacked corroboration of actual cash flow. The 40:60 partial sustenance was also held unsustainable.</description>
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      <link>https://www.taxtmi.com/caselaws?id=425954</link>
      <description>Reassessment challenge for want of a fresh section 143(2) notice after the assessee&#039;s belated request to treat the original return as filed in response to section 148 was rejected, as the request was beyond time and the Assessing Officer could proceed on the notices already issued. The addition for alleged unaccounted cash receipts on land sale was deleted because it was based on third-party loose sheets and a retracted statement that was not tested by cross-examination; the material was vague, not clearly linked to the assessee or the year in issue, and lacked corroboration of actual cash flow. The 40:60 partial sustenance was also held unsustainable.</description>
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