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    <title>2024 (9) TMI 1834 - ITAT HYDERABAD</title>
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    <description>ITAT Hyderabad held that reopening an assessment under s.147 after four years was invalid where the AO failed to record any finding that the assessee had not fully and truly disclosed material facts; the reassessment and consequent order dated 28-12-2019 were quashed. The Tribunal also found the disallowance of finance charges under s.36(1)(iii) unjustified, noting advances were used for business and loans to group companies had commercial nexus; it set aside the CIT(A)&#039;s partial confirmation and directed deletion of the addition. The assessee&#039;s appeal was allowed.</description>
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      <title>2024 (9) TMI 1834 - ITAT HYDERABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=464644</link>
      <description>ITAT Hyderabad held that reopening an assessment under s.147 after four years was invalid where the AO failed to record any finding that the assessee had not fully and truly disclosed material facts; the reassessment and consequent order dated 28-12-2019 were quashed. The Tribunal also found the disallowance of finance charges under s.36(1)(iii) unjustified, noting advances were used for business and loans to group companies had commercial nexus; it set aside the CIT(A)&#039;s partial confirmation and directed deletion of the addition. The assessee&#039;s appeal was allowed.</description>
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