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Reassessment founded on seized material requires a live and direct nexus between the material and the assessee. An inquiry-register entry held by a real-estate broker, which predated the land purchase, reflected land offered for sale and an asking rate rather than a completed transaction. As the entry neither identified nor linked the assessee or co-purchasers, and the named person was not examined, a survey-number match alone could not establish unrecorded consideration. The notice reopening assessment was therefore quashed as based on conjecture and surmise rather than material linked to the assessee.
Reassessment founded on seized material requires a live and direct nexus between the material and the assessee. An inquiry-register entry held by a real-estate broker, which predated the land purchase, reflected land offered for sale and an asking rate rather than a completed transaction. As the entry neither identified nor linked the assessee or co-purchasers, and the named person was not examined, a survey-number match alone could not establish unrecorded consideration. The notice reopening assessment was therefore quashed as based on conjecture and surmise rather than material linked to the assessee.
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