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    <title>2026 (7) TMI 34 - ITAT LUCKNOW</title>
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    <description>Non-disposal of objections to reopening before completion of reassessment violated natural justice and rendered the reassessment unsustainable. The assessee&#039;s objections to the reopening were on record, but the Assessing Officer did not consider or dispose of them before completing the assessment; the reassessment was therefore vitiated in the assessee&#039;s favour. Schedule-I of ITR-7 was held to cover only amounts accumulated or set apart under section 11(2), not deemed application under Explanation (1)(2) to section 11(1). The addition made for non-disclosure of deemed application was accordingly unsustainable and was deleted in the assessee&#039;s favour.</description>
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      <link>https://www.taxtmi.com/caselaws?id=794148</link>
      <description>Non-disposal of objections to reopening before completion of reassessment violated natural justice and rendered the reassessment unsustainable. The assessee&#039;s objections to the reopening were on record, but the Assessing Officer did not consider or dispose of them before completing the assessment; the reassessment was therefore vitiated in the assessee&#039;s favour. Schedule-I of ITR-7 was held to cover only amounts accumulated or set apart under section 11(2), not deemed application under Explanation (1)(2) to section 11(1). The addition made for non-disclosure of deemed application was accordingly unsustainable and was deleted in the assessee&#039;s favour.</description>
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