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    <title>2025 (1) TMI 1593 - ITAT CHANDIGARH</title>
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    <description>The ITAT Chandigarh held that the reopening notice issued under Section 148 dated 20.03.2019 was barred by limitation and bad in law, as the assessee had disclosed all material facts fully and truly during the original assessment under Section 143(3) read with 153A following a search under Section 132. The AO failed to prove any nondisclosure or concealment by the assessee. The alleged incriminating material was insufficient to treat the subcontractor parties as bogus, and the details were part of the original assessment record. Reliance was placed on judicial precedents affirming that reopening beyond four years without failure to disclose is invalid. Consequently, the notice and the consequential reassessment were quashed.</description>
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    <pubDate>Thu, 02 Jan 2025 00:00:00 +0530</pubDate>
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      <title>2025 (1) TMI 1593 - ITAT CHANDIGARH</title>
      <link>https://www.taxtmi.com/caselaws?id=463066</link>
      <description>The ITAT Chandigarh held that the reopening notice issued under Section 148 dated 20.03.2019 was barred by limitation and bad in law, as the assessee had disclosed all material facts fully and truly during the original assessment under Section 143(3) read with 153A following a search under Section 132. The AO failed to prove any nondisclosure or concealment by the assessee. The alleged incriminating material was insufficient to treat the subcontractor parties as bogus, and the details were part of the original assessment record. Reliance was placed on judicial precedents affirming that reopening beyond four years without failure to disclose is invalid. Consequently, the notice and the consequential reassessment were quashed.</description>
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      <pubDate>Thu, 02 Jan 2025 00:00:00 +0530</pubDate>
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