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    <title>2022 (10) TMI 1232 - ITAT PUNE</title>
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    <description>The ITAT Pune upheld the AO&#039;s reopening of assessment under section 147 based on large financial transactions and non-filing of ITR. The appellant company&#039;s director claimed ignorance of company activities after her husband&#039;s death, but this was rejected as the reply was received during proceedings. The tribunal found no violation of natural justice as proper notices were served under sections 148, 142(1), and 144. The addition under section 68 was confirmed as the assessee failed to establish the nature and source of cash credits with evidential material. The peak credit theory was rejected since the assessee couldn&#039;t prove money transfers through banking channels or creditor identity. Interest under sections 234B and 234C was held mandatory and consequential.</description>
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    <pubDate>Mon, 10 Oct 2022 00:00:00 +0530</pubDate>
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      <title>2022 (10) TMI 1232 - ITAT PUNE</title>
      <link>https://www.taxtmi.com/caselaws?id=312948</link>
      <description>The ITAT Pune upheld the AO&#039;s reopening of assessment under section 147 based on large financial transactions and non-filing of ITR. The appellant company&#039;s director claimed ignorance of company activities after her husband&#039;s death, but this was rejected as the reply was received during proceedings. The tribunal found no violation of natural justice as proper notices were served under sections 148, 142(1), and 144. The addition under section 68 was confirmed as the assessee failed to establish the nature and source of cash credits with evidential material. The peak credit theory was rejected since the assessee couldn&#039;t prove money transfers through banking channels or creditor identity. Interest under sections 234B and 234C was held mandatory and consequential.</description>
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      <pubDate>Mon, 10 Oct 2022 00:00:00 +0530</pubDate>
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