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Reassessment based on a suspicious transaction report cannot stand on mere suspicion without material indicating income escapement. The HC noted that the assessee's accounts and detailed reply showed the questioned receipts were capital contributions or withdrawals between a partner and its partnership firm; a partner's withdrawal of its capital balance does not itself establish taxable income. Revenue identified no evidence or third-party information that the bank entries were bogus or accommodation entries, and no related interest claim was disputed. The show-cause notice, reassessment notice and reassessment order were quashed.
Reassessment based on a suspicious transaction report cannot stand on mere suspicion without material indicating income escapement. The HC noted that the assessee's accounts and detailed reply showed the questioned receipts were capital contributions or withdrawals between a partner and its partnership firm; a partner's withdrawal of its capital balance does not itself establish taxable income. Revenue identified no evidence or third-party information that the bank entries were bogus or accommodation entries, and no related interest claim was disputed. The show-cause notice, reassessment notice and reassessment order were quashed.
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