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    <title>2025 (3) TMI 298 - ITAT KOLKATA</title>
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    <description>Reopening under sections 147 and 148 was held invalid where the assessment had already been completed under section 143(3) and the same unsecured loan transaction had been examined in the original proceedings. The reassessment reasons did not expressly record any failure by the assessee to disclose fully and truly all material facts, which is mandatory when reopening is initiated after four years from the end of the assessment year. As the issue had already been scrutinised and the statutory precondition was not met, the reassessment was quashed.</description>
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      <title>2025 (3) TMI 298 - ITAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=766913</link>
      <description>Reopening under sections 147 and 148 was held invalid where the assessment had already been completed under section 143(3) and the same unsecured loan transaction had been examined in the original proceedings. The reassessment reasons did not expressly record any failure by the assessee to disclose fully and truly all material facts, which is mandatory when reopening is initiated after four years from the end of the assessment year. As the issue had already been scrutinised and the statutory precondition was not met, the reassessment was quashed.</description>
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      <pubDate>Tue, 04 Mar 2025 00:00:00 +0530</pubDate>
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