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    <title>2025 (3) TMI 25 - ITAT BANGALORE</title>
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    <description>An issue that has already attained finality in earlier appellate proceedings cannot be reopened in a later appeal over the same concluded additions. The JDA-related income-tax additions, including treatment as business income and capital gains, had been finally decided in the earlier round; only the section 14A disallowance was remanded for fresh consideration. The Revenue&#039;s second round challenge sought to reopen those settled JDA additions, so the appeal on that issue was not maintainable and was dismissed in favour of the assessee.</description>
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      <link>https://www.taxtmi.com/caselaws?id=766640</link>
      <description>An issue that has already attained finality in earlier appellate proceedings cannot be reopened in a later appeal over the same concluded additions. The JDA-related income-tax additions, including treatment as business income and capital gains, had been finally decided in the earlier round; only the section 14A disallowance was remanded for fresh consideration. The Revenue&#039;s second round challenge sought to reopen those settled JDA additions, so the appeal on that issue was not maintainable and was dismissed in favour of the assessee.</description>
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