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    <title>2026 (4) TMI 1378 - ITAT NAGPUR</title>
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    <description>ITAT Nagpur held that a second reassessment based only on verification of bank credits, without fresh tangible material, amounted to a change of opinion and was not supported by a valid reason to believe; the reopening was therefore quashed. On merits, the assessee substantiated the source of the bank deposits with sale deeds, bank statements, fund-flow details and transfer evidence, which the Revenue did not effectively rebut in remand proceedings. The Tribunal held that the entire deposits could not be taxed under section 69A where part of the source was explained, and only any truly unexplained component could be brought to tax; the addition was deleted.</description>
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      <title>2026 (4) TMI 1378 - ITAT NAGPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=790309</link>
      <description>ITAT Nagpur held that a second reassessment based only on verification of bank credits, without fresh tangible material, amounted to a change of opinion and was not supported by a valid reason to believe; the reopening was therefore quashed. On merits, the assessee substantiated the source of the bank deposits with sale deeds, bank statements, fund-flow details and transfer evidence, which the Revenue did not effectively rebut in remand proceedings. The Tribunal held that the entire deposits could not be taxed under section 69A where part of the source was explained, and only any truly unexplained component could be brought to tax; the addition was deleted.</description>
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