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    <title>2021 (3) TMI 1479 - ITAT MUMBAI</title>
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    <description>A reassessment notice giving less than the statutory minimum time under section 148 was held jurisdictionally defective, and a later retrospective amendment did not cure a reassessment already concluded on that basis. Share market and related loss claims were largely accepted, including set-off treatment and short-term capital loss support from contract records. Ad hoc expense disallowances were restricted, section 14A disallowance was confined, and most additions under sections 69 and 69A were deleted where ownership or unexplained nature was not established. Interest expenditure was allowed on accrual, while interest under sections 234A, 234B and 234C remained applicable subject to TDS reduction. Appellate enhancement was struck down as beyond the remand scope and unsupported on merits.</description>
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      <link>https://www.taxtmi.com/caselaws?id=463299</link>
      <description>A reassessment notice giving less than the statutory minimum time under section 148 was held jurisdictionally defective, and a later retrospective amendment did not cure a reassessment already concluded on that basis. Share market and related loss claims were largely accepted, including set-off treatment and short-term capital loss support from contract records. Ad hoc expense disallowances were restricted, section 14A disallowance was confined, and most additions under sections 69 and 69A were deleted where ownership or unexplained nature was not established. Interest expenditure was allowed on accrual, while interest under sections 234A, 234B and 234C remained applicable subject to TDS reduction. Appellate enhancement was struck down as beyond the remand scope and unsupported on merits.</description>
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