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    <title>2024 (7) TMI 901 - ITAT JAIPUR</title>
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    <description>Reassessment under sections 147 and 148 was found unsustainable where the Assessing Officer relied on Investigation Wing material without independent verification and the recorded reasons were factually incorrect. The reopening rested on alleged fictitious equity and derivative profits, but the disclosed profits were accepted and the belief for reopening was treated as mechanically adopted rather than genuinely formed. The disallowance of share-trading loss also failed because the stated basis for reopening did not survive in the completed assessment, and no adequate material linked the assessee to manipulative trades. The reassessment and resulting additions were set aside.</description>
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      <link>https://www.taxtmi.com/caselaws?id=755681</link>
      <description>Reassessment under sections 147 and 148 was found unsustainable where the Assessing Officer relied on Investigation Wing material without independent verification and the recorded reasons were factually incorrect. The reopening rested on alleged fictitious equity and derivative profits, but the disclosed profits were accepted and the belief for reopening was treated as mechanically adopted rather than genuinely formed. The disallowance of share-trading loss also failed because the stated basis for reopening did not survive in the completed assessment, and no adequate material linked the assessee to manipulative trades. The reassessment and resulting additions were set aside.</description>
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