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    <title>2024 (6) TMI 595 - ITAT RAIPUR</title>
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    <description>The ITAT Raipur allowed the appeal and quashed the AO&#039;s order under sections 144 and 147. The AO had reopened assessment believing the assessee&#039;s property investment was from undisclosed income. However, the AO accepted the assessee&#039;s explanation with documentary evidence that investment was from disclosed sources and made no addition regarding the investment source. Instead, the AO made an independent addition under section 56(2)(vii)(b) for the difference between stamp duty value and purchase consideration. The ITAT held that since the AO didn&#039;t make any addition regarding the original basis for reopening (investment source), he lacked jurisdiction to make the independent addition under section 56(2)(vii)(b), having traversed beyond his jurisdictional scope.</description>
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    <pubDate>Tue, 28 May 2024 00:00:00 +0530</pubDate>
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      <title>2024 (6) TMI 595 - ITAT RAIPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=753988</link>
      <description>The ITAT Raipur allowed the appeal and quashed the AO&#039;s order under sections 144 and 147. The AO had reopened assessment believing the assessee&#039;s property investment was from undisclosed income. However, the AO accepted the assessee&#039;s explanation with documentary evidence that investment was from disclosed sources and made no addition regarding the investment source. Instead, the AO made an independent addition under section 56(2)(vii)(b) for the difference between stamp duty value and purchase consideration. The ITAT held that since the AO didn&#039;t make any addition regarding the original basis for reopening (investment source), he lacked jurisdiction to make the independent addition under section 56(2)(vii)(b), having traversed beyond his jurisdictional scope.</description>
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      <pubDate>Tue, 28 May 2024 00:00:00 +0530</pubDate>
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