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    <title>2023 (12) TMI 409 - ITAT DELHI</title>
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    <description>ITAT Delhi dismissed the assessee&#039;s appeal challenging reassessment proceedings under Section 147. The tribunal held that notice under Section 143(2) issued on 12/09/2017 was valid despite being issued after the time limit for filing return in response to Section 148 notice. The AO had sufficient reason to believe income escaped assessment, making the reopening valid. Sanction under Section 151 was properly obtained. Addition under Section 68 was upheld as the assessee failed to prove identity, capacity, and genuineness of creditors. The reassessment order was deemed valid and all grounds of appeal were dismissed.</description>
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    <pubDate>Tue, 05 Dec 2023 00:00:00 +0530</pubDate>
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      <title>2023 (12) TMI 409 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=446725</link>
      <description>ITAT Delhi dismissed the assessee&#039;s appeal challenging reassessment proceedings under Section 147. The tribunal held that notice under Section 143(2) issued on 12/09/2017 was valid despite being issued after the time limit for filing return in response to Section 148 notice. The AO had sufficient reason to believe income escaped assessment, making the reopening valid. Sanction under Section 151 was properly obtained. Addition under Section 68 was upheld as the assessee failed to prove identity, capacity, and genuineness of creditors. The reassessment order was deemed valid and all grounds of appeal were dismissed.</description>
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      <pubDate>Tue, 05 Dec 2023 00:00:00 +0530</pubDate>
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