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    <title>2025 (9) TMI 98 - ITAT DELHI</title>
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    <description>ITAT DELHI - AT upheld reopening under section 147 as initial non-filing left cash deposits unexplained, but directed deletion of additions by AO after concluding the assessee&#039;s bank and fund-flow statements established sufficient withdrawn cash re-deposited, and the claimed opening balances from earlier years were not open to doubt. The return filed late was treated as invalid so no section 143(2) notice was required. The assessment framed under section 144 was set aside to the extent of the impugned addition, and section 115BBE was held not to apply.</description>
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    <pubDate>Thu, 28 Aug 2025 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=777609</link>
      <description>ITAT DELHI - AT upheld reopening under section 147 as initial non-filing left cash deposits unexplained, but directed deletion of additions by AO after concluding the assessee&#039;s bank and fund-flow statements established sufficient withdrawn cash re-deposited, and the claimed opening balances from earlier years were not open to doubt. The return filed late was treated as invalid so no section 143(2) notice was required. The assessment framed under section 144 was set aside to the extent of the impugned addition, and section 115BBE was held not to apply.</description>
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