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    <title>2024 (12) TMI 256 - GUJARAT HIGH COURT</title>
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    <description>Reopening under section 147 was treated as valid where the reassessment was based on Investigation Wing information indicating accommodation entries and bogus purchase bills, and there was no factual basis to insist on exclusive recourse to section 153C. The addition on disputed purchases was also sustained at 6% because the purchases were linked to an accommodation-entry group, sales were not doubted, and the estimate was supported by concurrent factual findings. No substantial question of law arose in section 260A proceedings.</description>
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      <description>Reopening under section 147 was treated as valid where the reassessment was based on Investigation Wing information indicating accommodation entries and bogus purchase bills, and there was no factual basis to insist on exclusive recourse to section 153C. The addition on disputed purchases was also sustained at 6% because the purchases were linked to an accommodation-entry group, sales were not doubted, and the estimate was supported by concurrent factual findings. No substantial question of law arose in section 260A proceedings.</description>
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