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    <title>Reopening under Sections 147/148 and Section 148A quashed; Section 43CA addition deleted for lack of new material</title>
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    <description>ITAT held that the reopening under sections 147/148 and the section 148A notice were invalid as issued on the same facts and documents already verified during original assessment, constituting a prohibited change of opinion; no new material was brought on record by the AO to sustain reopening. The Tribunal also deleted the addition under section 43CA, finding the stamp duty value-agreement value variance below the 5% margin applicable to AY 2016-17, and directed the AO to delete the impugned addition. Grounds raised by the Assessee in respect of the reopening and the section 43CA addition were allowed.</description>
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    <pubDate>Wed, 10 Sep 2025 08:39:56 +0530</pubDate>
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      <title>Reopening under Sections 147/148 and Section 148A quashed; Section 43CA addition deleted for lack of new material</title>
      <link>https://www.taxtmi.com/highlights?id=92375</link>
      <description>ITAT held that the reopening under sections 147/148 and the section 148A notice were invalid as issued on the same facts and documents already verified during original assessment, constituting a prohibited change of opinion; no new material was brought on record by the AO to sustain reopening. The Tribunal also deleted the addition under section 43CA, finding the stamp duty value-agreement value variance below the 5% margin applicable to AY 2016-17, and directed the AO to delete the impugned addition. Grounds raised by the Assessee in respect of the reopening and the section 43CA addition were allowed.</description>
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      <pubDate>Wed, 10 Sep 2025 08:39:56 +0530</pubDate>
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