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    <title>2024 (1) TMI 109 - ITAT GUWAHATI</title>
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    <description>ITAT Guwahati held that AO&#039;s conversion of limited scrutiny to complete scrutiny was invalid as it lacked necessary approval from competent authority and was not based on credible material showing possibility of income understatement. The conversion violated CBDT mandate requiring reasonable view based on reliable information with direct nexus to under-assessment. Additionally, the addition under section 69A regarding unsecured loans was deleted as assessee had discharged burden by providing complete details including PAN numbers, identity, and creditworthiness of creditors through banking channels. AO failed to bring controverting material despite issuing notices under section 131. Appeal decided in favor of assessee.</description>
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    <pubDate>Wed, 29 Nov 2023 00:00:00 +0530</pubDate>
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      <title>2024 (1) TMI 109 - ITAT GUWAHATI</title>
      <link>https://www.taxtmi.com/caselaws?id=447710</link>
      <description>ITAT Guwahati held that AO&#039;s conversion of limited scrutiny to complete scrutiny was invalid as it lacked necessary approval from competent authority and was not based on credible material showing possibility of income understatement. The conversion violated CBDT mandate requiring reasonable view based on reliable information with direct nexus to under-assessment. Additionally, the addition under section 69A regarding unsecured loans was deleted as assessee had discharged burden by providing complete details including PAN numbers, identity, and creditworthiness of creditors through banking channels. AO failed to bring controverting material despite issuing notices under section 131. Appeal decided in favor of assessee.</description>
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