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    <title>2025 (9) TMI 8 - ITAT MUMBAI</title>
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    <description>ITAT MUMBAI - AT held that the assessing officer&#039;s additions for an alleged undisclosed HSBC Geneva account were unsustainable: the BUP ID referenced in the bank &quot;base note&quot; was a name identifier linked to an already-assessed profile, not a separate undisclosed account, and the AO erred in making substantive additions on mere presumption. Reopenings for A.Y. 2001-02 to 2005-06 were invalid as barred by limitation and cannot be revived by subsequent legislative amendment; the reassessments therefore were quashed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=777519</link>
      <description>ITAT MUMBAI - AT held that the assessing officer&#039;s additions for an alleged undisclosed HSBC Geneva account were unsustainable: the BUP ID referenced in the bank &quot;base note&quot; was a name identifier linked to an already-assessed profile, not a separate undisclosed account, and the AO erred in making substantive additions on mere presumption. Reopenings for A.Y. 2001-02 to 2005-06 were invalid as barred by limitation and cannot be revived by subsequent legislative amendment; the reassessments therefore were quashed.</description>
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