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    <title>2025 (2) TMI 1715 - ITAT AGRA</title>
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    <description>A liberal approach to delay condonation was applied because the assessee showed sufficient cause for the 314-day delay, and the delay was condoned. On reassessment, the recorded reason for reopening was capital gains computation under section 50C, but the final addition was made under section 69A as unexplained money. As the addition rested on a ground different and unrelated to the reason recorded for reopening, the reassessment lacked a sustainable legal foundation and was quashed. The assessee succeeded on both the preliminary limitation issue and the jurisdictional challenge to the reassessment.</description>
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      <link>https://www.taxtmi.com/caselaws?id=467679</link>
      <description>A liberal approach to delay condonation was applied because the assessee showed sufficient cause for the 314-day delay, and the delay was condoned. On reassessment, the recorded reason for reopening was capital gains computation under section 50C, but the final addition was made under section 69A as unexplained money. As the addition rested on a ground different and unrelated to the reason recorded for reopening, the reassessment lacked a sustainable legal foundation and was quashed. The assessee succeeded on both the preliminary limitation issue and the jurisdictional challenge to the reassessment.</description>
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