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    <title>2025 (7) TMI 1477 - ITAT MUMBAI</title>
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    <description>The ITAT Mumbai held that reassessment proceedings under section 147 were initiated based on information about unexplained cash deposits linked to a shell entity. The tribunal found no record of the assessee&#039;s objections to the reasons for reopening being disposed of before finalizing the assessment. Since the assessment order did not address the objections, the ITAT directed the matter to be restored to the file of the Ld. CIT(A) for fresh adjudication on the additional grounds after verifying the assessment records and providing the assessee an opportunity of hearing. The appeal was partly allowed, emphasizing adherence to procedural fairness as per the Supreme Court&#039;s ruling in GKN Driveshaft.</description>
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      <description>The ITAT Mumbai held that reassessment proceedings under section 147 were initiated based on information about unexplained cash deposits linked to a shell entity. The tribunal found no record of the assessee&#039;s objections to the reasons for reopening being disposed of before finalizing the assessment. Since the assessment order did not address the objections, the ITAT directed the matter to be restored to the file of the Ld. CIT(A) for fresh adjudication on the additional grounds after verifying the assessment records and providing the assessee an opportunity of hearing. The appeal was partly allowed, emphasizing adherence to procedural fairness as per the Supreme Court&#039;s ruling in GKN Driveshaft.</description>
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