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    <title>2025 (3) TMI 301 - ITAT MUMBAI</title>
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    <description>ITAT Mumbai ruled in favor of the assessee, quashing reassessment proceedings initiated under section 147. The tribunal held that the AO failed to record valid reasons believing income had escaped assessment due to non-disclosure of material facts. The reasons recorded were silent on this crucial allegation, which was impermissibly added later while disposing objections. The reassessment was based on case records already considered during original scrutiny assessment under section 143(3), with no new tangible material. The proceedings were deemed bad in law and non-compliant with section 147 provisions.</description>
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      <description>ITAT Mumbai ruled in favor of the assessee, quashing reassessment proceedings initiated under section 147. The tribunal held that the AO failed to record valid reasons believing income had escaped assessment due to non-disclosure of material facts. The reasons recorded were silent on this crucial allegation, which was impermissibly added later while disposing objections. The reassessment was based on case records already considered during original scrutiny assessment under section 143(3), with no new tangible material. The proceedings were deemed bad in law and non-compliant with section 147 provisions.</description>
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