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    <title>2026 (1) TMI 1200 - ITAT PUNE</title>
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    <description>Validity of reassessment under section 148 was contested on grounds that the Assessing Officer lacked new tangible material and merely changed opinion on matters earlier examined under assessment proceedings u/s.143(3); accordingly reassessment was quashed for being a review of the original order. Addition treated as unexplained income under section 68 relating to unsecured loans was deleted because the assessee furnished bank records, PAN, confirmations, 7/12 extracts and evidence that lenders were agriculturists with taxable income, discharging the primary onus. Disallowance under section 40(a)(ia) for interest paid to an NBFC was directed back to the AO for verification and production of Form 27BA.</description>
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      <title>2026 (1) TMI 1200 - ITAT PUNE</title>
      <link>https://www.taxtmi.com/caselaws?id=785444</link>
      <description>Validity of reassessment under section 148 was contested on grounds that the Assessing Officer lacked new tangible material and merely changed opinion on matters earlier examined under assessment proceedings u/s.143(3); accordingly reassessment was quashed for being a review of the original order. Addition treated as unexplained income under section 68 relating to unsecured loans was deleted because the assessee furnished bank records, PAN, confirmations, 7/12 extracts and evidence that lenders were agriculturists with taxable income, discharging the primary onus. Disallowance under section 40(a)(ia) for interest paid to an NBFC was directed back to the AO for verification and production of Form 27BA.</description>
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