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    <description>Reassessment under section 148 requires recorded reasons based on specific, reliable and relevant material objectively showing escapement of income; a tax evasion report or borrowed satisfaction, without corroboration, is insufficient. On the facts noted, the reopening failed because the alleged bank deposits were not substantiated and the attributed statement was incomplete and unreliable, so the reassessment was invalid. Additions made on the same unsupported material, including in later assessment years reopened on the same basis, also could not stand and were deleted.</description>
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      <description>Reassessment under section 148 requires recorded reasons based on specific, reliable and relevant material objectively showing escapement of income; a tax evasion report or borrowed satisfaction, without corroboration, is insufficient. On the facts noted, the reopening failed because the alleged bank deposits were not substantiated and the attributed statement was incomplete and unreliable, so the reassessment was invalid. Additions made on the same unsupported material, including in later assessment years reopened on the same basis, also could not stand and were deleted.</description>
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