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    <title>2025 (2) TMI 229 - ITAT KOLKATA</title>
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    <description>The ITAT Kolkata quashed reopening proceedings initiated by the AO for unexplained cash credit under section 68. The AO failed to establish tangible nexus between information received from Investigation Wing about cash deposits and the specific transactions of the assessee. The AO did not identify the company through which alleged sums were received, nor verify if transactions were already declared in audited balance sheets. The reopening after four years lacked proper reasons to believe income had escaped assessment, constituting borrowed satisfaction without independent application of mind. Despite the assessee providing detailed explanations of share application money transactions, no enquiry was conducted. Following South Yarra Holdings precedent, the tribunal held reassessment proceedings invalid due to absence of tangible material and decided in favor of the assessee.</description>
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    <pubDate>Tue, 04 Feb 2025 00:00:00 +0530</pubDate>
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      <title>2025 (2) TMI 229 - ITAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=765683</link>
      <description>The ITAT Kolkata quashed reopening proceedings initiated by the AO for unexplained cash credit under section 68. The AO failed to establish tangible nexus between information received from Investigation Wing about cash deposits and the specific transactions of the assessee. The AO did not identify the company through which alleged sums were received, nor verify if transactions were already declared in audited balance sheets. The reopening after four years lacked proper reasons to believe income had escaped assessment, constituting borrowed satisfaction without independent application of mind. Despite the assessee providing detailed explanations of share application money transactions, no enquiry was conducted. Following South Yarra Holdings precedent, the tribunal held reassessment proceedings invalid due to absence of tangible material and decided in favor of the assessee.</description>
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      <pubDate>Tue, 04 Feb 2025 00:00:00 +0530</pubDate>
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