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    <title>2025 (8) TMI 843 - ITAT AHMEDABAD</title>
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    <description>The ITAT AHMEDABAD upheld the reopening of assessment u/s 147, finding that the AO&#039;s use of the entity name M/s. Kushal Limited was valid as it was a renamed M/s. Kushal Tradelink Limited. The approval for issuance of notice u/s 148 was also held valid, rejecting CIT(A)&#039;s view of invalidity. However, the tribunal upheld CIT(A)&#039;s deletion of additions relating to alleged bogus LTCG and STCG, as the assessee had disclosed transactions and paid tax, with no evidence of accommodation entries from the AO. Similarly, the addition of commission paid for obtaining accommodation entries was deleted due to lack of evidence. Grounds raised by the Revenue challenging the deletions were dismissed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=776655</link>
      <description>The ITAT AHMEDABAD upheld the reopening of assessment u/s 147, finding that the AO&#039;s use of the entity name M/s. Kushal Limited was valid as it was a renamed M/s. Kushal Tradelink Limited. The approval for issuance of notice u/s 148 was also held valid, rejecting CIT(A)&#039;s view of invalidity. However, the tribunal upheld CIT(A)&#039;s deletion of additions relating to alleged bogus LTCG and STCG, as the assessee had disclosed transactions and paid tax, with no evidence of accommodation entries from the AO. Similarly, the addition of commission paid for obtaining accommodation entries was deleted due to lack of evidence. Grounds raised by the Revenue challenging the deletions were dismissed.</description>
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