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    <title>2025 (3) TMI 1863 - ITAT MUMBAI</title>
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    <description>Reassessment under section 148A was held invalid where the Revenue did not supply the material and working basis for the proposed escapement, did not fairly consider the assessee&#039;s reply, and relied on fresh material in the final order that had not been confronted in the show-cause notice. On the merits, the disallowance of contingency expenses was deleted because the assessee produced invoices, work orders, bills, confirmations and related records, while the Revenue brought no positive evidence that the expenditure was bogus or non-business. The disallowance of fees for technical services was also deleted, as agreements, invoices, correspondence and other project records supported actual rendering of services and a blanket disallowance under section 37(1) was unsustainable.</description>
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      <link>https://www.taxtmi.com/caselaws?id=469786</link>
      <description>Reassessment under section 148A was held invalid where the Revenue did not supply the material and working basis for the proposed escapement, did not fairly consider the assessee&#039;s reply, and relied on fresh material in the final order that had not been confronted in the show-cause notice. On the merits, the disallowance of contingency expenses was deleted because the assessee produced invoices, work orders, bills, confirmations and related records, while the Revenue brought no positive evidence that the expenditure was bogus or non-business. The disallowance of fees for technical services was also deleted, as agreements, invoices, correspondence and other project records supported actual rendering of services and a blanket disallowance under section 37(1) was unsustainable.</description>
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