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    <title>2025 (8) TMI 1362 - ITAT RAIPUR</title>
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    <description>ITAT upheld validity of the reopening, finding departmental approval on the ITBA portal dated 29.03.2018 authorized issuance of notice under section 148; that contention was decided against the assessee. The PBPT adjudication, however, classified the transaction as benami and identified two joint beneficial owners, so the entire investment cannot be treated as unexplained in the assessee&#039;s hands under section 69. The VSVS application was held not to be a conclusive admission. Ld. CIT(A)&#039;s order was set aside and the case remitted to the AO to rework additions and allocate quantum between joint beneficial owners in line with PBPT directions.</description>
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      <title>2025 (8) TMI 1362 - ITAT RAIPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=777174</link>
      <description>ITAT upheld validity of the reopening, finding departmental approval on the ITBA portal dated 29.03.2018 authorized issuance of notice under section 148; that contention was decided against the assessee. The PBPT adjudication, however, classified the transaction as benami and identified two joint beneficial owners, so the entire investment cannot be treated as unexplained in the assessee&#039;s hands under section 69. The VSVS application was held not to be a conclusive admission. Ld. CIT(A)&#039;s order was set aside and the case remitted to the AO to rework additions and allocate quantum between joint beneficial owners in line with PBPT directions.</description>
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