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    <title>2025 (6) TMI 1628 - ITAT MUMBAI</title>
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    <description>Reassessment was held unsustainable where the recorded reasons were undated, based on unverified information, and showed no independent enquiry or application of mind by the Assessing Officer, so jurisdiction to reopen could not stand. The addition under section 56(2)(vii)(c) for alleged receipt of gifted shares was also found unjustified because the shares had already been gifted and transferred before the taxing provision became applicable, and later execution of gift deeds did not alter the completed transfer. The impugned addition was therefore deleted.</description>
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      <description>Reassessment was held unsustainable where the recorded reasons were undated, based on unverified information, and showed no independent enquiry or application of mind by the Assessing Officer, so jurisdiction to reopen could not stand. The addition under section 56(2)(vii)(c) for alleged receipt of gifted shares was also found unjustified because the shares had already been gifted and transferred before the taxing provision became applicable, and later execution of gift deeds did not alter the completed transfer. The impugned addition was therefore deleted.</description>
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