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    <title>2025 (2) TMI 122 - ITAT AHMEDABAD</title>
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    <description>Reassessment was upheld where the Assessing Officer acted on fresh tangible material from DGCEI proceedings, including seized diary entries, cash-trail evidence and corroborative statements, which provided a rational basis to believe income had escaped assessment. The taxpayer failed to show any procedural defect in the reopening. On the merits, unaccounted sales were established through the seized material and third-party admissions, but only the profit element embedded in such turnover was taxable, not the entire sales figure. The first appellate estimate of 6% was treated as a reasonable basis on the record, giving partial relief to the assessee.</description>
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      <link>https://www.taxtmi.com/caselaws?id=765576</link>
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