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    <title>2025 (12) TMI 147 - ITAT, RAIPUR</title>
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    <description>ITAT, Raipur upheld the treatment of the assessee&#039;s electronically filed return as invalid due to non-compliance with the requirement to send the physical acknowledgement to CPC within 30 days, holding that an invalid return is equivalent to non-filing. However, it quashed the reassessment initiated u/s 147/148, finding that the &quot;reasons to believe&quot; were recorded without independent application of mind and were perverse and arbitrary, particularly as there was no sale transaction in the relevant year. The Tribunal held that such defective reasons could not confer valid jurisdiction on the AO, and the reassessment order was therefore invalid and liable to be set aside.</description>
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    <pubDate>Mon, 04 Aug 2025 00:00:00 +0530</pubDate>
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      <title>2025 (12) TMI 147 - ITAT, RAIPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=782607</link>
      <description>ITAT, Raipur upheld the treatment of the assessee&#039;s electronically filed return as invalid due to non-compliance with the requirement to send the physical acknowledgement to CPC within 30 days, holding that an invalid return is equivalent to non-filing. However, it quashed the reassessment initiated u/s 147/148, finding that the &quot;reasons to believe&quot; were recorded without independent application of mind and were perverse and arbitrary, particularly as there was no sale transaction in the relevant year. The Tribunal held that such defective reasons could not confer valid jurisdiction on the AO, and the reassessment order was therefore invalid and liable to be set aside.</description>
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