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    <title>2024 (11) TMI 758 - ITAT AMRITSAR</title>
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    <description>ITAT Amritsar held that reassessment proceedings initiated after four years were invalid as the AO failed to establish that the assessee had not disclosed all material facts necessary for assessment. The tribunal found that reopening was based on change of opinion rather than failure to disclose, citing SC precedents in Canara Bank and Virbac Animal Health cases. Regarding bogus purchases, the tribunal determined that purchases were genuine as sales were properly recorded, VAT returns filed, and goods&#039; ultimate destination at Thermal Plant was transparent. The entire transaction chain from purchase to final utilization was examined during original assessment without defects. Addition on account of bogus purchases was deleted, deciding in favor of assessee.</description>
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    <pubDate>Thu, 19 Sep 2024 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=761772</link>
      <description>ITAT Amritsar held that reassessment proceedings initiated after four years were invalid as the AO failed to establish that the assessee had not disclosed all material facts necessary for assessment. The tribunal found that reopening was based on change of opinion rather than failure to disclose, citing SC precedents in Canara Bank and Virbac Animal Health cases. Regarding bogus purchases, the tribunal determined that purchases were genuine as sales were properly recorded, VAT returns filed, and goods&#039; ultimate destination at Thermal Plant was transparent. The entire transaction chain from purchase to final utilization was examined during original assessment without defects. Addition on account of bogus purchases was deleted, deciding in favor of assessee.</description>
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