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    <title>2025 (8) TMI 1090 - ITAT AHMEDABAD</title>
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    <description>ITAT held that AO had tangible material and a reasonable belief to reopen assessment under s.147, so reopening was valid. However, additions under s.68 were unsustainable: amounts already recorded as sales in books (with corresponding purchases not doubted) cannot be taxed again under s.68 as this would double-tax the same income. Further, additions rested solely on a third-party statement without opportunity for cross-examination and without independent inquiry by AO. Consequently, the s.68 additions were deleted and the appeal was allowed in favour of the assessee.</description>
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    <pubDate>Wed, 08 Jan 2025 00:00:00 +0530</pubDate>
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      <title>2025 (8) TMI 1090 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=776902</link>
      <description>ITAT held that AO had tangible material and a reasonable belief to reopen assessment under s.147, so reopening was valid. However, additions under s.68 were unsustainable: amounts already recorded as sales in books (with corresponding purchases not doubted) cannot be taxed again under s.68 as this would double-tax the same income. Further, additions rested solely on a third-party statement without opportunity for cross-examination and without independent inquiry by AO. Consequently, the s.68 additions were deleted and the appeal was allowed in favour of the assessee.</description>
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