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    <title>2025 (11) TMI 1077 - BOMBAY HIGH COURT</title>
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    <description>The HC set aside reassessment proceedings and allowed the petition, holding that no income chargeable to tax had escaped assessment. The assessee had declared and offered to tax the disputed sum; investigation material did not identify the assessee as a beneficiary of accommodation entries; and the reasons recorded for reopening were insufficient. A recorded error naming a different company and the unremarked approval by higher authorities demonstrated a mechanical, non-application of mind in sanctioning reassessment. Reopening and sanction were therefore unsustainable in law.</description>
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      <description>The HC set aside reassessment proceedings and allowed the petition, holding that no income chargeable to tax had escaped assessment. The assessee had declared and offered to tax the disputed sum; investigation material did not identify the assessee as a beneficiary of accommodation entries; and the reasons recorded for reopening were insufficient. A recorded error naming a different company and the unremarked approval by higher authorities demonstrated a mechanical, non-application of mind in sanctioning reassessment. Reopening and sanction were therefore unsustainable in law.</description>
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