https://www.taxtmi.com/caselaws?id=775162 ITAT Pune dismissed Revenue's appeal challenging CIT(A)'s order quashing reassessment proceedings under section 147. The case involved reopening assessment beyond four years for disallowance of capital gains exemption under section 10(38) and unexplained expenditure under section 69C related to penny stock transactions. The original assessment was completed under section 143(3) read with 153A where AO had already considered and allowed the expenditure claim after examining assessee's replies. ITAT held that without fresh tangible material, reassessment for the same transaction was impermissible, citing Chanchal Bhagwatilal Gokhru vs. Union of India where Bombay HC ruled similarly. The tribunal found no infirmity in CIT(A)'s detailed reasoning and upheld the order dismissing Revenue's grounds. en-us Thu, 17 Jul 2025 00:00:00 +0530 Sat, 19 Jul 2025 12:27:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775162 ITAT Pune dismissed Revenue's appeal challenging CIT(A)'s order quashing reassessment proceedings under section 147. The case involved reopening assessment beyond four years for disallowance of capital gains exemption under section 10(38) and unexplained expenditure under section 69C related to penny stock transactions. The original assessment was completed under section 143(3) read with 153A where AO had already considered and allowed the expenditure claim after examining assessee's replies. ITAT held that without fresh tangible material, reassessment for the same transaction was impermissible, citing Chanchal Bhagwatilal Gokhru vs. Union of India where Bombay HC ruled similarly. The tribunal found no infirmity in CIT(A)'s detailed reasoning and upheld the order dismissing Revenue's grounds. Case-Laws Income Tax Thu, 17 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775162