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    <title>2024 (11) TMI 1025 - ITAT DELHI</title>
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    <description>The ITAT Delhi held that the reassessment proceedings were invalid and quashed the assessment order. The tribunal found that the Assessing Officer failed to establish proper &quot;reasons to believe&quot; for reopening the assessment, as there was no coherence between the stated reasons for reopening and the actual additions made. The AO alleged bogus purchases but made no specific addition based on those reasons. The tribunal emphasized that additions cannot be made on grounds different from those recorded for reopening, and third-party statements recorded after the initial reasons cannot justify reopening. The appeal was allowed in favor of the assessee.</description>
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    <pubDate>Tue, 19 Nov 2024 00:00:00 +0530</pubDate>
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      <title>2024 (11) TMI 1025 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=762039</link>
      <description>The ITAT Delhi held that the reassessment proceedings were invalid and quashed the assessment order. The tribunal found that the Assessing Officer failed to establish proper &quot;reasons to believe&quot; for reopening the assessment, as there was no coherence between the stated reasons for reopening and the actual additions made. The AO alleged bogus purchases but made no specific addition based on those reasons. The tribunal emphasized that additions cannot be made on grounds different from those recorded for reopening, and third-party statements recorded after the initial reasons cannot justify reopening. The appeal was allowed in favor of the assessee.</description>
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      <pubDate>Tue, 19 Nov 2024 00:00:00 +0530</pubDate>
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