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    <title>2025 (12) TMI 423 - ITAT AHMEDABAD</title>
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    <description>ITAT Ahmedabad held that reassessment u/s 147 r.w.s. 148 was valid where the AO independently recorded reasons based on information regarding bogus long-term capital gains, despite a search on a third party. Since the AO did not rely solely on material seized in the third-party search, the assessee&#039;s contention that proceedings ought to have been initiated u/s 153C was rejected, and Grounds 2 and 3 were dismissed. However, in respect of additions u/s 69A and 69C, ITAT observed that CIT(A) had not examined the merits or the evidentiary material produced. The issue of such additions was remanded to CIT(A) for fresh adjudication in accordance with law.</description>
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    <pubDate>Wed, 03 Dec 2025 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=782883</link>
      <description>ITAT Ahmedabad held that reassessment u/s 147 r.w.s. 148 was valid where the AO independently recorded reasons based on information regarding bogus long-term capital gains, despite a search on a third party. Since the AO did not rely solely on material seized in the third-party search, the assessee&#039;s contention that proceedings ought to have been initiated u/s 153C was rejected, and Grounds 2 and 3 were dismissed. However, in respect of additions u/s 69A and 69C, ITAT observed that CIT(A) had not examined the merits or the evidentiary material produced. The issue of such additions was remanded to CIT(A) for fresh adjudication in accordance with law.</description>
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