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    <title>2025 (12) TMI 739 - ITAT AHMEDABAD</title>
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    <description>ITAT held that the PCIT&#039;s assumption of jurisdiction u/s 263 was invalid and quashed the revisional order. It found that the AO had duly examined the transactions forming the basis of reopening, which pertained to alleged unsecured loans from a corporate entity. The bank account, though in the assessee&#039;s name, was established to be operated and controlled by a third party, and all related transactions had already been taxed in that third party&#039;s hands. As the Revenue produced no evidence of actual unsecured loans to the assessee and the impugned sum matched the already assessed transactions, the reassessment premise was factually incorrect. The assessee&#039;s appeal was allowed.</description>
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    <pubDate>Tue, 09 Dec 2025 00:00:00 +0530</pubDate>
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      <title>2025 (12) TMI 739 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=783199</link>
      <description>ITAT held that the PCIT&#039;s assumption of jurisdiction u/s 263 was invalid and quashed the revisional order. It found that the AO had duly examined the transactions forming the basis of reopening, which pertained to alleged unsecured loans from a corporate entity. The bank account, though in the assessee&#039;s name, was established to be operated and controlled by a third party, and all related transactions had already been taxed in that third party&#039;s hands. As the Revenue produced no evidence of actual unsecured loans to the assessee and the impugned sum matched the already assessed transactions, the reassessment premise was factually incorrect. The assessee&#039;s appeal was allowed.</description>
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