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    <title>2024 (4) TMI 1133 - ITAT AHMEDABAD</title>
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    <description>The ITAT Ahmedabad upheld reassessment proceedings u/s 147 against an assessee who had unexplained cash deposits of Rs. 28.70 crores in a Renukamata Society bank account but failed to file returns. The tribunal found the assessee was not the real beneficiary of deposits, which were operated by actual depositors in collusion with the society. The tribunal assessed only 0.25% of deposits as taxable income representing commission for allowing account misuse. Penalty u/s 271(1)(b) for non-compliance with notices was deleted, finding the assessee had reasonable cause as the society assured their tax professional would handle proceedings.</description>
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      <link>https://www.taxtmi.com/caselaws?id=456005</link>
      <description>The ITAT Ahmedabad upheld reassessment proceedings u/s 147 against an assessee who had unexplained cash deposits of Rs. 28.70 crores in a Renukamata Society bank account but failed to file returns. The tribunal found the assessee was not the real beneficiary of deposits, which were operated by actual depositors in collusion with the society. The tribunal assessed only 0.25% of deposits as taxable income representing commission for allowing account misuse. Penalty u/s 271(1)(b) for non-compliance with notices was deleted, finding the assessee had reasonable cause as the society assured their tax professional would handle proceedings.</description>
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