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    <title>2023 (11) TMI 233 - ITAT MUMBAI</title>
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    <description>Reopening under sections 147 and 148 was upheld because tangible material from investigation, abnormal scrip movement and bank and return verification supported a prima facie belief of escapement of income; minor defects in the recorded reasons did not invalidate the reopening. The addition for alleged bogus long-term capital gain and accommodation entry was not sustained because the SEBI order related to disclosure defaults, not price rigging or manipulation, and the Revenue did not independently prove that the share transactions were sham or linked to any entry operator. On this reasoning, the reassessment survived but the substantive addition was deleted.</description>
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      <link>https://www.taxtmi.com/caselaws?id=445342</link>
      <description>Reopening under sections 147 and 148 was upheld because tangible material from investigation, abnormal scrip movement and bank and return verification supported a prima facie belief of escapement of income; minor defects in the recorded reasons did not invalidate the reopening. The addition for alleged bogus long-term capital gain and accommodation entry was not sustained because the SEBI order related to disclosure defaults, not price rigging or manipulation, and the Revenue did not independently prove that the share transactions were sham or linked to any entry operator. On this reasoning, the reassessment survived but the substantive addition was deleted.</description>
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