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    <title>2025 (7) TMI 591 - ITAT DELHI</title>
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    <description>ITAT Delhi held that reassessment notice u/s 148 issued on 28.03.2019 was valid as it was within the six-year limitation period under section 149(1)(b), despite being served later. The tribunal applied section 292BB due to assessee&#039;s participation in proceedings. However, ITAT allowed the appeal regarding unexplained investment u/s 69, ruling that AO failed to discharge burden of proof after assessee provided adequate documentation of loan transactions. AO was directed to delete the addition as no independent verification was conducted to challenge assessee&#039;s explanation regarding lenders&#039; identity and creditworthiness.</description>
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      <title>2025 (7) TMI 591 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=774523</link>
      <description>ITAT Delhi held that reassessment notice u/s 148 issued on 28.03.2019 was valid as it was within the six-year limitation period under section 149(1)(b), despite being served later. The tribunal applied section 292BB due to assessee&#039;s participation in proceedings. However, ITAT allowed the appeal regarding unexplained investment u/s 69, ruling that AO failed to discharge burden of proof after assessee provided adequate documentation of loan transactions. AO was directed to delete the addition as no independent verification was conducted to challenge assessee&#039;s explanation regarding lenders&#039; identity and creditworthiness.</description>
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