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    <title>2024 (5) TMI 1659 - ITAT KOLKATA</title>
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    <description>Reopening of assessment beyond four years was found unsustainable because the assessee had disclosed and produced evidence regarding unsecured loans during original proceedings, so reopening amounted to change of opinion and was quashed. Additions under the unexplained credit head were rejected where identity, creditworthiness and genuineness were established by PAN, financial and bank records, repayments through banking channels and TDS compliance, shifting burden back to authorities who failed to discharge it. A suo motu disallowance linked to exempt investment income was set aside because disallowance exceeded the exempt income and own funds sufficed to cover the investments, directing deletion of the addition.</description>
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    <pubDate>Wed, 22 May 2024 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=466024</link>
      <description>Reopening of assessment beyond four years was found unsustainable because the assessee had disclosed and produced evidence regarding unsecured loans during original proceedings, so reopening amounted to change of opinion and was quashed. Additions under the unexplained credit head were rejected where identity, creditworthiness and genuineness were established by PAN, financial and bank records, repayments through banking channels and TDS compliance, shifting burden back to authorities who failed to discharge it. A suo motu disallowance linked to exempt investment income was set aside because disallowance exceeded the exempt income and own funds sufficed to cover the investments, directing deletion of the addition.</description>
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