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    Contractual reimbursement of incremental GST cannot override statutory GST returns, interest, penalty or limitation rules
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    Additional ITC anti-profiteering analysis upheld on project-wise methodology, recipient-specific restitution, interest, and no retrospective penalty.
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      Reassessment cannot be sustained where the reason to believe is...

      Reason to believe for reassessment fails where reopening rests on sister-concern material and presumed on-money sales.

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      Income TaxJuly 8, 2026Case LawsHC
      Reassessment cannot be sustained where the reason to believe is founded on presumptions drawn from a sister concern's records rather than material showing escapement in the assessee's own case. The Court found that alleged on-money receipts were inferred by assuming a cash component in the petitioner's sales merely because another group entity faced allegations of unaccounted receipts, with only a director's profit-sharing interest and an Excel file in his Gmail account as the connecting material. The section 148 notice was quashed.

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      ActsIncome Tax