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    <title>2025 (2) TMI 1742 - ITAT MUMBAI</title>
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    <description>Fresh and tangible information from another charge can validly support reopening under section 147 when the issue was not examined earlier and no prior opinion existed; the challenge based on change of opinion and the first proviso to section 147 failed. The unsecured loan and related commission were not treated as unexplained or bogus because the assessee produced loan confirmation, financial statements, bank trail, repayment evidence, and TDS records, while the record did not show any cash trail or other material disproving genuineness. The additions under sections 69A and 69C were deleted, though the reassessment itself was sustained.</description>
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    <pubDate>Fri, 14 Feb 2025 00:00:00 +0530</pubDate>
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      <title>2025 (2) TMI 1742 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=467916</link>
      <description>Fresh and tangible information from another charge can validly support reopening under section 147 when the issue was not examined earlier and no prior opinion existed; the challenge based on change of opinion and the first proviso to section 147 failed. The unsecured loan and related commission were not treated as unexplained or bogus because the assessee produced loan confirmation, financial statements, bank trail, repayment evidence, and TDS records, while the record did not show any cash trail or other material disproving genuineness. The additions under sections 69A and 69C were deleted, though the reassessment itself was sustained.</description>
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      <pubDate>Fri, 14 Feb 2025 00:00:00 +0530</pubDate>
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