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    <title>2025 (1) TMI 502 - ITAT KOLKATA</title>
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    <description>ITAT Kolkata held that reopening of assessment under sections 147 and 148 was invalid and bad in law. The assessee had disclosed commodity profits including Rs. 20 lacs through transactions with a commodity company, which the department could not controvert. The tribunal found that reopening was based on information received from investigation wing without independent application of mind or tangible material, constituting impermissible borrowed satisfaction. The assessment was decided in favor of the assessee, with support from Delhi HC precedent in Meenakshi Overseas case.</description>
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      <title>2025 (1) TMI 502 - ITAT KOLKATA</title>
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      <description>ITAT Kolkata held that reopening of assessment under sections 147 and 148 was invalid and bad in law. The assessee had disclosed commodity profits including Rs. 20 lacs through transactions with a commodity company, which the department could not controvert. The tribunal found that reopening was based on information received from investigation wing without independent application of mind or tangible material, constituting impermissible borrowed satisfaction. The assessment was decided in favor of the assessee, with support from Delhi HC precedent in Meenakshi Overseas case.</description>
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