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    <title>2025 (10) TMI 1220 - ITAT DELHI</title>
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    <description>Reassessment beyond four years under sections 147 and 148 was considered sustainable where tangible material from the Investigation Wing indicated that the purchaser was a shell entity involved in accommodation entries and the original record did not reveal those facts. The receipts shown as sale consideration were also treated as unexplained cash credit under section 68 because the surrounding circumstances suggested a sham sale, including negligible business activity, no credible source of funds, no registered conveyance, no timely transfer of possession, and a bank trail consistent with routing unaccounted money. Procedural objections based on non-confrontation of statements and delayed disposal of reopening objections were rejected for want of demonstrated prejudice.</description>
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      <link>https://www.taxtmi.com/caselaws?id=780423</link>
      <description>Reassessment beyond four years under sections 147 and 148 was considered sustainable where tangible material from the Investigation Wing indicated that the purchaser was a shell entity involved in accommodation entries and the original record did not reveal those facts. The receipts shown as sale consideration were also treated as unexplained cash credit under section 68 because the surrounding circumstances suggested a sham sale, including negligible business activity, no credible source of funds, no registered conveyance, no timely transfer of possession, and a bank trail consistent with routing unaccounted money. Procedural objections based on non-confrontation of statements and delayed disposal of reopening objections were rejected for want of demonstrated prejudice.</description>
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