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    <title>2025 (7) TMI 1657 - ITAT JAIPUR</title>
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    <description>The ITAT Jaipur held that the reopening of assessment under section 147 was invalid as the approval letter was improperly issued by an unauthorized officer and consolidated for multiple independent assessees without proper application of mind by the Pr. CIT, violating section 151. Consequently, the notice under section 148 and subsequent proceedings were quashed. Regarding unexplained investment under section 69, the CIT(A) failed to exercise co-terminus powers to verify the affidavit filed by the assessee, and the evidence was wrongly rejected; thus, additions were deleted. Penalty under section 271(1)(c) for non-compliance with notices was also deleted considering the appellant&#039;s occupation and genuine reasons for non-compliance. The appeal was allowed in entirety.</description>
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    <pubDate>Tue, 03 Jun 2025 00:00:00 +0530</pubDate>
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      <title>2025 (7) TMI 1657 - ITAT JAIPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=775589</link>
      <description>The ITAT Jaipur held that the reopening of assessment under section 147 was invalid as the approval letter was improperly issued by an unauthorized officer and consolidated for multiple independent assessees without proper application of mind by the Pr. CIT, violating section 151. Consequently, the notice under section 148 and subsequent proceedings were quashed. Regarding unexplained investment under section 69, the CIT(A) failed to exercise co-terminus powers to verify the affidavit filed by the assessee, and the evidence was wrongly rejected; thus, additions were deleted. Penalty under section 271(1)(c) for non-compliance with notices was also deleted considering the appellant&#039;s occupation and genuine reasons for non-compliance. The appeal was allowed in entirety.</description>
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      <pubDate>Tue, 03 Jun 2025 00:00:00 +0530</pubDate>
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