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    <title>2025 (3) TMI 1683 - ITAT RAJKOT</title>
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    <description>Reassessment under the Income-tax Act was upheld because the reopening was based on information of large cash deposits and non-filing of return, and no contemporaneous objection to the section 148 notice was raised during assessment. The challenge to jurisdiction therefore failed. Additions for cash deposits and alleged commission income were not finally sustained because the assessee claimed the deposits belonged to beneficiaries, but complete beneficiary particulars were not verified and adequate opportunity had not been granted. The matter was remanded to the Assessing Officer for fresh adjudication after allowing the assessee to produce names, addresses, PAN details and the beneficiaries for verification and cross-examination.</description>
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      <title>2025 (3) TMI 1683 - ITAT RAJKOT</title>
      <link>https://www.taxtmi.com/caselaws?id=469071</link>
      <description>Reassessment under the Income-tax Act was upheld because the reopening was based on information of large cash deposits and non-filing of return, and no contemporaneous objection to the section 148 notice was raised during assessment. The challenge to jurisdiction therefore failed. Additions for cash deposits and alleged commission income were not finally sustained because the assessee claimed the deposits belonged to beneficiaries, but complete beneficiary particulars were not verified and adequate opportunity had not been granted. The matter was remanded to the Assessing Officer for fresh adjudication after allowing the assessee to produce names, addresses, PAN details and the beneficiaries for verification and cross-examination.</description>
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