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    <title>2025 (4) TMI 1430 - ITAT MUMBAI</title>
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    <description>ITAT Mumbai held that reopening of assessment u/s 147 beyond four years cannot be sustained based on audit objection when facts were already disclosed in financial accounts and computation of income. The tribunal found that since specific queries were answered with proper disclosure during original assessment, the audit objection did not constitute tangible material justifying reopening. The notice u/s 148 was quashed along with the resultant assessment order. The P.V.S. Beedies precedent was distinguished as it applies only when audit reveals facts unknown to AO originally. Decision favoured assessee.</description>
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    <pubDate>Tue, 08 Apr 2025 00:00:00 +0530</pubDate>
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      <title>2025 (4) TMI 1430 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=769516</link>
      <description>ITAT Mumbai held that reopening of assessment u/s 147 beyond four years cannot be sustained based on audit objection when facts were already disclosed in financial accounts and computation of income. The tribunal found that since specific queries were answered with proper disclosure during original assessment, the audit objection did not constitute tangible material justifying reopening. The notice u/s 148 was quashed along with the resultant assessment order. The P.V.S. Beedies precedent was distinguished as it applies only when audit reveals facts unknown to AO originally. Decision favoured assessee.</description>
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      <pubDate>Tue, 08 Apr 2025 00:00:00 +0530</pubDate>
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