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    <title>2025 (7) TMI 663 - ITAT MUMBAI</title>
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    <description>The ITAT Mumbai held that approval under Section 151 for reopening assessment was invalid as it lacked proper signature, making the Section 148 notice and subsequent assessment order bad in law. The tribunal established that digital signature is mandatory for electronically communicated notices per Section 282A, not merely a formality. Regarding income additions, the tribunal ruled that scrap sale income should be assessed as business income rather than unexplained money under Section 69A, allowing estimated additions based on profit percentages. Out-of-books expenses additions were deleted as they were already covered in scrap sale estimations. Salary splitting arrangements between employees and spouses were held legitimate, reversing disallowances. The tribunal upheld partial disallowances for purchases lacking proper documentation but deleted additions based on diary entries where explanations were provided and cash balances were adequately supported by regular books.</description>
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    <pubDate>Thu, 03 Jul 2025 00:00:00 +0530</pubDate>
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      <title>2025 (7) TMI 663 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=774595</link>
      <description>The ITAT Mumbai held that approval under Section 151 for reopening assessment was invalid as it lacked proper signature, making the Section 148 notice and subsequent assessment order bad in law. The tribunal established that digital signature is mandatory for electronically communicated notices per Section 282A, not merely a formality. Regarding income additions, the tribunal ruled that scrap sale income should be assessed as business income rather than unexplained money under Section 69A, allowing estimated additions based on profit percentages. Out-of-books expenses additions were deleted as they were already covered in scrap sale estimations. Salary splitting arrangements between employees and spouses were held legitimate, reversing disallowances. The tribunal upheld partial disallowances for purchases lacking proper documentation but deleted additions based on diary entries where explanations were provided and cash balances were adequately supported by regular books.</description>
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      <pubDate>Thu, 03 Jul 2025 00:00:00 +0530</pubDate>
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