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Section 2506 Section 1476 Section 271(1)(c)6 Section 1444 Section 251(1)(a)2 Section 69A2 Section 44A2 Cash Deposit2 Penalty2 Reassessment

DINESH JAT,SAGAR vs. CIT (A), SAGAR

ITA 195/JAB/2025[2013-2014]Status: DisposedITAT Jabalpur28 Aug 2025AY 2013-2014

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Jaiswal Sancheti, C.AFor Respondent: Shri. N.M. Prasad, Sr. DR

Section 144Section 147Section 250Section 251(1)(a)Section 271(1)(c)Section 44ASection 69A

Reassessment is Without Proper Foundation - Absence of Tangible Material The reopening of the assessment under section 147 is purely based on AIR-reported bank deposits without any independent verification or tangible evidence. This amounts to a borrowed satisfaction, which has been consistently held by judicial forums (including Harmeet Singh vs. ITO) as invalid and unsustainable in law. 5. Addition

DINESH JAT,SAGAR vs. CIT (A), SAGAR

DINESH JAT,SAGAR vs. CIT (A), SAGAR

DINESH JAT,SAGAR vs. CIT(A), NFAC