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    <title>2025 (3) TMI 2161 - ITAT SURAT</title>
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    <description>A jurisdictional challenge to reassessment is described as incapable of being defeated by waiver, acquiescence or estoppel, requiring merits-based consideration where it was not adjudicated at the first appellate stage. The note further addresses unsecured loans: repayment through banking channels, accepted by the Department and supported by transaction evidence, may preclude an unexplained cash-credit addition where evidentiary requirements are met. Mere prolonged non-repayment of outstanding loans is stated to be insufficient for such an addition without examining identity, creditworthiness and genuineness, or considering possible cessation-of-liability provisions. The repaid-loan relief is described as intact, while reassessment and outstanding-loan issues require fresh determination.</description>
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      <description>A jurisdictional challenge to reassessment is described as incapable of being defeated by waiver, acquiescence or estoppel, requiring merits-based consideration where it was not adjudicated at the first appellate stage. The note further addresses unsecured loans: repayment through banking channels, accepted by the Department and supported by transaction evidence, may preclude an unexplained cash-credit addition where evidentiary requirements are met. Mere prolonged non-repayment of outstanding loans is stated to be insufficient for such an addition without examining identity, creditworthiness and genuineness, or considering possible cessation-of-liability provisions. The repaid-loan relief is described as intact, while reassessment and outstanding-loan issues require fresh determination.</description>
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