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    <title>2026 (5) TMI 1323 - ITAT AHMEDABAD</title>
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    <description>Reassessment based on cash deposits and time deposits could not be used to sustain a separate disallowance of deduction under section 80P when no addition was made on the recorded reasons for reopening. The assessment accepted the explanation for the deposits, so the original basis for reassessment did not survive. In that situation, an independent addition on an unrelated issue was impermissible. The disallowance of deduction under section 80P was therefore deleted in favour of the assessee, and the addition was set aside.</description>
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      <link>https://www.taxtmi.com/caselaws?id=792121</link>
      <description>Reassessment based on cash deposits and time deposits could not be used to sustain a separate disallowance of deduction under section 80P when no addition was made on the recorded reasons for reopening. The assessment accepted the explanation for the deposits, so the original basis for reassessment did not survive. In that situation, an independent addition on an unrelated issue was impermissible. The disallowance of deduction under section 80P was therefore deleted in favour of the assessee, and the addition was set aside.</description>
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