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| The Tax Publishers2020 TaxPub(DT) 3267 (Pune-Trib) INCOME TAX ACT, 1961
Section 147
In the absence of any tangible material, assumption of reassessment jurisdiction on the reason of mere verification of certain loan transactions was not valid.
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Reassessment - No tangible material - Reopening for mere verification of certain loan transactions -
AO in order to verify genuineness of certain loan transactions, reopened assessment by issuing notice under section 148 and thus, made addition. Assessee challenged reopening as invalid. Held: In the absence of any tangible material, assumption of reassessment jurisdiction on the reason of mere verification, was not valid.
Relied:Nivi Trading Ltd. v. UOI (2015) 275 ITR 308 (Bom) : 2015 TaxPub(DT) 2227 (Bom-HC) and Mr. Lalchand Mehrumal Jagwani ITA No. 1241/PUN. 2019.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2009-10
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