#Section 147
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Registration Not Determinative; Stock-in-Trade Taxable on Possession & Consideration – Rs 10.81 Cr Deleted – ITAT Mumbai
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Reassessment Quashed: Sec 143(2) Notice Mandatory in 147 Cases; Return Filed Within TOLA Time Valid – ITAT Kolkata
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Reassessment Beyond 3 Years Void for PCIT Approval Instead of PCCIT – ITAT Mumbai
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Sec 68 Addition on Share Capital & Premium Deleted: No AO Enquiry; High Premium Not Enough – ITAT Kolkata
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Non-Application of Mind and Wrong AY Render Sec 147 Reopening Void – ITAT Kolkata
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Penalty U/s 271D & 271E Deleted – Partner Capital Cash Not Covered U/s 269SS/269T: ITAT Kolkata
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Sec 69 Addition Deleted – NRI Property Funded by Overseas Remittances via Mother’s Bank Trail – ITAT Mumbai
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Reopening Quashed: Mechanical Sec 151 Approval Invalid; Rubber-Stamp Sanction Cannot Sustain Sec 147 – ITAT Kolkata
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Bogus Purchase Addition Restricted to 5% as Sales Accepted & Banking Trail Proven: ITAT Mumbai
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NFAC Reassessment Void Without Sec 151A Notice – Assessment & 271(1)(c) Penalty Deleted – ITAT Kolkata
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Section 68 Addition Deleted for Want of Cross-Examination; Three Ingredients Proved – ITAT Kolkata
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Reopening Invalid: Sec 148 Notice Before Sec 151 Approval Communication – Jurisdictional Defect Fatal – ITAT Kolkata
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Borrowed Satisfaction and Mechanical U/s 151 Approval Invalidate 147 Reopening – ITAT Kolkata
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