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    <title>2025 (2) TMI 1636 - ITAT MUMBAI</title>
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    <description>Reopening jurisdiction must be confined to the specific reasons recorded: where reassessment was initiated on alleged bogus invoices the assessing officer was required to investigate and make additions only on that basis; additions made without addressing the recorded reasons are unsustainable. Similarly, an assessing officer cannot gross up sales for tax adjustments while ignoring corresponding purchases where the assessee operates an exclusive system of accounting and the accounting treatment was not controverted. Operative effect: such additions and the reassessment as executed were held invalid and the appeal in favour of the assessee was allowed.</description>
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      <description>Reopening jurisdiction must be confined to the specific reasons recorded: where reassessment was initiated on alleged bogus invoices the assessing officer was required to investigate and make additions only on that basis; additions made without addressing the recorded reasons are unsustainable. Similarly, an assessing officer cannot gross up sales for tax adjustments while ignoring corresponding purchases where the assessee operates an exclusive system of accounting and the accounting treatment was not controverted. Operative effect: such additions and the reassessment as executed were held invalid and the appeal in favour of the assessee was allowed.</description>
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