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    <title>2024 (9) TMI 1935 - ITAT BANGALORE</title>
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    <description>Reassessment under section 147 was upheld because the Assessing Officer cross-verified Investigation Wing information with the assessee&#039;s balance sheet and formed an independent prima facie view of escapement of income, rather than acting mechanically on borrowed satisfaction. The addition under section 69A for alleged unexplained jewellery purchases was deleted because a third-party excel sheet, without independent corroboration, was insufficient to prove unaccounted investment by the assessee; the relied-upon statements did not conclusively establish the purchase, fair cross-examination was not effectively afforded, and the material also did not match the relevant assessment year. The reassessment stood, but the addition failed.</description>
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      <title>2024 (9) TMI 1935 - ITAT BANGALORE</title>
      <link>https://www.taxtmi.com/caselaws?id=469539</link>
      <description>Reassessment under section 147 was upheld because the Assessing Officer cross-verified Investigation Wing information with the assessee&#039;s balance sheet and formed an independent prima facie view of escapement of income, rather than acting mechanically on borrowed satisfaction. The addition under section 69A for alleged unexplained jewellery purchases was deleted because a third-party excel sheet, without independent corroboration, was insufficient to prove unaccounted investment by the assessee; the relied-upon statements did not conclusively establish the purchase, fair cross-examination was not effectively afforded, and the material also did not match the relevant assessment year. The reassessment stood, but the addition failed.</description>
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