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    <title>2025 (5) TMI 895 - GUJARAT HIGH COURT</title>
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    <description>Reassessment notice was not struck down on territorial jurisdiction grounds because the assessee remained within the same jurisdiction, had earlier filed its return before the issuing Assessing Officer, and did not establish timely intimation of any jurisdictional change after the name and PAN alteration. However, the reopening failed on merits because the recorded reasons based on portal information did not disclose concrete transaction-level material linking the assessee to alleged escapement of income. A mere suspicion or generic reference to accommodation entries and cash deposits was treated as a fishing inquiry, so the notice was quashed for want of a bona fide reason to believe.</description>
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      <description>Reassessment notice was not struck down on territorial jurisdiction grounds because the assessee remained within the same jurisdiction, had earlier filed its return before the issuing Assessing Officer, and did not establish timely intimation of any jurisdictional change after the name and PAN alteration. However, the reopening failed on merits because the recorded reasons based on portal information did not disclose concrete transaction-level material linking the assessee to alleged escapement of income. A mere suspicion or generic reference to accommodation entries and cash deposits was treated as a fishing inquiry, so the notice was quashed for want of a bona fide reason to believe.</description>
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