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    <title>2025 (5) TMI 2303 - ITAT PUNE</title>
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    <description>Reassessment based on survey material was held bad in law where the recorded reasons were materially mistaken, the assessee had already been scrutinised, and no direct material linked the assessee to any sham mutual fund transaction or knowing participation in manipulation. The reopening therefore failed. The exempt dividend claim was also upheld because the investment and receipt were supported by banking records, the fund house confirmed compliance in dividend declaration, and allegations against the fund house alone could not justify denial of exemption absent evidence against the assessee. The consequential addition was deleted and the Revenue&#039;s challenge failed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=469452</link>
      <description>Reassessment based on survey material was held bad in law where the recorded reasons were materially mistaken, the assessee had already been scrutinised, and no direct material linked the assessee to any sham mutual fund transaction or knowing participation in manipulation. The reopening therefore failed. The exempt dividend claim was also upheld because the investment and receipt were supported by banking records, the fund house confirmed compliance in dividend declaration, and allegations against the fund house alone could not justify denial of exemption absent evidence against the assessee. The consequential addition was deleted and the Revenue&#039;s challenge failed.</description>
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