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    <title>2025 (12) TMI 1172 - ITAT CUTTACK</title>
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    <description>Reassessment beyond four years was invalid where it rested solely on the Justice M.B. Shah Commission report without independent verification and without showing failure by the assessee to fully and truly disclose material facts; the reopening was quashed. The addition for alleged suppressed production and illegal mining also failed because the production figures in the mining return and tax audit report tallied, and no independent evidence established unrecorded production or sales; the addition was deleted. Disallowance under Explanation 1 to section 37(1) likewise failed because the payments were business-related mining expenses and no offence, penalty, or statutory prohibition was shown; the disallowance was deleted.</description>
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    <pubDate>Thu, 11 Dec 2025 00:00:00 +0530</pubDate>
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      <title>2025 (12) TMI 1172 - ITAT CUTTACK</title>
      <link>https://www.taxtmi.com/caselaws?id=783632</link>
      <description>Reassessment beyond four years was invalid where it rested solely on the Justice M.B. Shah Commission report without independent verification and without showing failure by the assessee to fully and truly disclose material facts; the reopening was quashed. The addition for alleged suppressed production and illegal mining also failed because the production figures in the mining return and tax audit report tallied, and no independent evidence established unrecorded production or sales; the addition was deleted. Disallowance under Explanation 1 to section 37(1) likewise failed because the payments were business-related mining expenses and no offence, penalty, or statutory prohibition was shown; the disallowance was deleted.</description>
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