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    <title>2025 (7) TMI 1308 - ITAT KOLKATA</title>
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    <description>A fresh reopening under sections 147 and 148 based on the same bank-account material was not permissible where that material had already formed the basis of an earlier reassessment and the matter had been settled under the Vivad Se Vishwas scheme. The tribunal treated the earlier round as having attained finality on the same accommodation-entry deposits, so the subsequent reassessment was founded on concluded material rather than new reason to believe. The reassessment reopening was therefore held invalid and quashed.</description>
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      <title>2025 (7) TMI 1308 - ITAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=775240</link>
      <description>A fresh reopening under sections 147 and 148 based on the same bank-account material was not permissible where that material had already formed the basis of an earlier reassessment and the matter had been settled under the Vivad Se Vishwas scheme. The tribunal treated the earlier round as having attained finality on the same accommodation-entry deposits, so the subsequent reassessment was founded on concluded material rather than new reason to believe. The reassessment reopening was therefore held invalid and quashed.</description>
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