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    <title>2025 (6) TMI 402 - ITAT MUMBAI</title>
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    <description>ITAT Mumbai allowed the appeal, setting aside the reopening of assessment under Section 147. The tribunal found that the assessee had adequately explained the source of investment in immovable property through documentary evidence of fixed deposit maturity proceeds. The AO&#039;s assumption that cash deposits were unexplained was deemed conjectural and unsupported by facts. The addition under Section 56(2)(viib) was ruled unjustified as this provision was not applicable to AY 2011-12, having come into effect from AY 2014-15. The matter was restored to the AO for fresh examination, granting the assessee opportunity to present evidence effectively.</description>
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      <title>2025 (6) TMI 402 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=772289</link>
      <description>ITAT Mumbai allowed the appeal, setting aside the reopening of assessment under Section 147. The tribunal found that the assessee had adequately explained the source of investment in immovable property through documentary evidence of fixed deposit maturity proceeds. The AO&#039;s assumption that cash deposits were unexplained was deemed conjectural and unsupported by facts. The addition under Section 56(2)(viib) was ruled unjustified as this provision was not applicable to AY 2011-12, having come into effect from AY 2014-15. The matter was restored to the AO for fresh examination, granting the assessee opportunity to present evidence effectively.</description>
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