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    <title>2025 (2) TMI 1931 - ITAT ALLAHABAD</title>
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    <description>Notice under section 143(2) was not required where no valid return had been filed in response to notice under section 148 within the time allowed; a belated or non est return did not trigger that procedural mandate, so reassessment under sections 147 and 144 was upheld. On merits, the assessee failed to prove third-party funding, identity, creditworthiness, genuineness, or supporting bank records for the freehold charges, so the amount was treated as unexplained expenditure under section 69C. The Revenue&#039;s treatment of capital gains, rejection of the cost of improvement claim, 10% disallowance of expenses, and characterization of the gains as short-term capital gains were all sustained for want of proof.</description>
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      <title>2025 (2) TMI 1931 - ITAT ALLAHABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=468874</link>
      <description>Notice under section 143(2) was not required where no valid return had been filed in response to notice under section 148 within the time allowed; a belated or non est return did not trigger that procedural mandate, so reassessment under sections 147 and 144 was upheld. On merits, the assessee failed to prove third-party funding, identity, creditworthiness, genuineness, or supporting bank records for the freehold charges, so the amount was treated as unexplained expenditure under section 69C. The Revenue&#039;s treatment of capital gains, rejection of the cost of improvement claim, 10% disallowance of expenses, and characterization of the gains as short-term capital gains were all sustained for want of proof.</description>
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