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    <title>2025 (3) TMI 299 - ITAT KOLKATA</title>
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    <description>The ITAT Kolkata held that the assessment reopening under section 147 was invalid as the AO failed to provide complete transaction details and acted on borrowed satisfaction without independent application of mind. The reasons recorded were vague and unambiguous, violating statutory provisions. On merits, the section 68 addition was also deleted as the AO relied solely on search statements without independent verification, denied cross-examination requests, and ignored that loans were fully repaid with supporting evidence. The CIT(A)&#039;s decision favoring the assessee was upheld.</description>
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      <title>2025 (3) TMI 299 - ITAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=766914</link>
      <description>The ITAT Kolkata held that the assessment reopening under section 147 was invalid as the AO failed to provide complete transaction details and acted on borrowed satisfaction without independent application of mind. The reasons recorded were vague and unambiguous, violating statutory provisions. On merits, the section 68 addition was also deleted as the AO relied solely on search statements without independent verification, denied cross-examination requests, and ignored that loans were fully repaid with supporting evidence. The CIT(A)&#039;s decision favoring the assessee was upheld.</description>
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