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    <title>2025 (12) TMI 585 - ITAT CHANDIGARH</title>
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    <description>ITAT set aside the reassessment initiated u/s 147 on the allegation of bogus purchases. The AO had reopened the assessment solely on the basis of information from the Investigation Wing and a third-party statement indicating issuance of bogus bills, without any independent, concrete material linking the assessee to such accommodation entries. ITAT noted that the assessee&#039;s transactions were duly recorded in GST returns and payments were made through banking channels, and that CIT(A)&#039;s conclusions were based on mere suspicion unsupported by documentary evidence. Holding that &quot;reason to believe&quot; cannot rest on uncorroborated information alone, ITAT declared the reopening invalid, vitiated the entire reassessment proceedings, and allowed the assessee&#039;s appeal.</description>
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      <title>2025 (12) TMI 585 - ITAT CHANDIGARH</title>
      <link>https://www.taxtmi.com/caselaws?id=783045</link>
      <description>ITAT set aside the reassessment initiated u/s 147 on the allegation of bogus purchases. The AO had reopened the assessment solely on the basis of information from the Investigation Wing and a third-party statement indicating issuance of bogus bills, without any independent, concrete material linking the assessee to such accommodation entries. ITAT noted that the assessee&#039;s transactions were duly recorded in GST returns and payments were made through banking channels, and that CIT(A)&#039;s conclusions were based on mere suspicion unsupported by documentary evidence. Holding that &quot;reason to believe&quot; cannot rest on uncorroborated information alone, ITAT declared the reopening invalid, vitiated the entire reassessment proceedings, and allowed the assessee&#039;s appeal.</description>
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