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    <title>2024 (12) TMI 1640 - ITAT CHANDIGARH</title>
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    <description>ITAT CHANDIGARH - AT held that reopening under s.147 was unsustainable because the AO failed to establish that the assessee was the real owner of cash deposited in her bank. The assessee, as donee, satisfactorily explained the deposits as gifts from the donor (spouse), supported by a gift deed, the donor&#039;s personal confirmation, and evidence of the donor&#039;s sale of agricultural land as source of funds. The AO&#039;s partial disallowance splitting the tranches was not sustained. The additions were deleted and the AO directed to grant relief to the assessee.</description>
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    <pubDate>Fri, 06 Dec 2024 00:00:00 +0530</pubDate>
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      <title>2024 (12) TMI 1640 - ITAT CHANDIGARH</title>
      <link>https://www.taxtmi.com/caselaws?id=464323</link>
      <description>ITAT CHANDIGARH - AT held that reopening under s.147 was unsustainable because the AO failed to establish that the assessee was the real owner of cash deposited in her bank. The assessee, as donee, satisfactorily explained the deposits as gifts from the donor (spouse), supported by a gift deed, the donor&#039;s personal confirmation, and evidence of the donor&#039;s sale of agricultural land as source of funds. The AO&#039;s partial disallowance splitting the tranches was not sustained. The additions were deleted and the AO directed to grant relief to the assessee.</description>
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