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    <title>2023 (3) TMI 1105 - ITAT MUMBAI</title>
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    <description>The Tribunal dismissed all appeals by the Revenue and allowed the petitions filed by the assessees, holding that the Assessing Officer lacked jurisdiction to make additions under section 147 of the Income Tax Act as they were not based on the reasons recorded for reopening the assessments. Consequently, the Revenue&#039;s grounds on merits were dismissed, and the additions made were deemed invalid.</description>
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      <description>The Tribunal dismissed all appeals by the Revenue and allowed the petitions filed by the assessees, holding that the Assessing Officer lacked jurisdiction to make additions under section 147 of the Income Tax Act as they were not based on the reasons recorded for reopening the assessments. Consequently, the Revenue&#039;s grounds on merits were dismissed, and the additions made were deemed invalid.</description>
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