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    <title>2023 (2) TMI 840 - ITAT INDORE</title>
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    <description>The ITAT upheld the validity of the reassessment order under sections 143(3) and 147 of the Income Tax Act, 1961, despite a reversal in the initial conclusion regarding a loan transaction. The reassessment was deemed reasonable based on the information available at the time. However, the penalty imposed under section 271D was quashed as it was found to be based on assumptions without concrete evidence, with the ITAT emphasizing that the provisions of sections 271D and 271E apply to loans taken, not given. The revenue&#039;s appeal was dismissed as infructuous following the quashing of the penalty order.</description>
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      <title>2023 (2) TMI 840 - ITAT INDORE</title>
      <link>https://www.taxtmi.com/caselaws?id=434325</link>
      <description>The ITAT upheld the validity of the reassessment order under sections 143(3) and 147 of the Income Tax Act, 1961, despite a reversal in the initial conclusion regarding a loan transaction. The reassessment was deemed reasonable based on the information available at the time. However, the penalty imposed under section 271D was quashed as it was found to be based on assumptions without concrete evidence, with the ITAT emphasizing that the provisions of sections 271D and 271E apply to loans taken, not given. The revenue&#039;s appeal was dismissed as infructuous following the quashing of the penalty order.</description>
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