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    <title>2025 (8) TMI 525 - ITAT BANGALORE</title>
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    <description>The ITAT Bangalore held that reopening assessment under section 147 was invalid as all material facts were disclosed during the original assessment under section 143(3). The AO&#039;s reliance on assumptions without tangible evidence failed to establish that the assessee escaped assessment. The AO could not prove that the cash deposits were dubious or that the assessee concealed income. Since the assessment was completed with full disclosure of primary facts, the notice issued under section 148 after four years was held illegal and void ab initio. The appeal by the assessee was allowed.</description>
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      <title>2025 (8) TMI 525 - ITAT BANGALORE</title>
      <link>https://www.taxtmi.com/caselaws?id=776338</link>
      <description>The ITAT Bangalore held that reopening assessment under section 147 was invalid as all material facts were disclosed during the original assessment under section 143(3). The AO&#039;s reliance on assumptions without tangible evidence failed to establish that the assessee escaped assessment. The AO could not prove that the cash deposits were dubious or that the assessee concealed income. Since the assessment was completed with full disclosure of primary facts, the notice issued under section 148 after four years was held illegal and void ab initio. The appeal by the assessee was allowed.</description>
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      <pubDate>Mon, 06 Jan 2025 00:00:00 +0530</pubDate>
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