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    <title>2025 (6) TMI 561 - ITAT PUNE</title>
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    <description>ITAT Pune allowed the assessee&#039;s appeal, quashing reassessment proceedings under section 147. The court held that reopening assessment after three years requires sanction from Principal Chief Commissioner or equivalent authority, but approval was given by Joint Commissioner/Additional Commissioner who lacked competence. Additionally, the tribunal deleted additions for unexplained investment in immovable property, finding the assessee was merely a power of attorney holder for actual purchasers who were clearly identified in sale deeds with their PANs, and properties were reflected in purchasers&#039; balance sheets.</description>
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      <title>2025 (6) TMI 561 - ITAT PUNE</title>
      <link>https://www.taxtmi.com/caselaws?id=772448</link>
      <description>ITAT Pune allowed the assessee&#039;s appeal, quashing reassessment proceedings under section 147. The court held that reopening assessment after three years requires sanction from Principal Chief Commissioner or equivalent authority, but approval was given by Joint Commissioner/Additional Commissioner who lacked competence. Additionally, the tribunal deleted additions for unexplained investment in immovable property, finding the assessee was merely a power of attorney holder for actual purchasers who were clearly identified in sale deeds with their PANs, and properties were reflected in purchasers&#039; balance sheets.</description>
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