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    <title>2024 (5) TMI 910 - ITAT DELHI</title>
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    <description>Reassessment under sections 147 and 148 may be sustained where prior approval is shown to have been obtained and the objection to sanction is unsupported by material. However, if the reassessment was initiated only to verify cash deposits and the assessee substantiates that the deposits came from sale of agricultural land, the revenue cannot travel beyond the recorded reasons and make additions on a different footing. The operative principle is that reassessment inquiry remains confined to the basis on which reopening was recorded, and additions unrelated to that basis are not sustainable once the source is explained on record.</description>
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      <link>https://www.taxtmi.com/caselaws?id=752857</link>
      <description>Reassessment under sections 147 and 148 may be sustained where prior approval is shown to have been obtained and the objection to sanction is unsupported by material. However, if the reassessment was initiated only to verify cash deposits and the assessee substantiates that the deposits came from sale of agricultural land, the revenue cannot travel beyond the recorded reasons and make additions on a different footing. The operative principle is that reassessment inquiry remains confined to the basis on which reopening was recorded, and additions unrelated to that basis are not sustainable once the source is explained on record.</description>
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