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    <title>2026 (1) TMI 125 - ITAT DELHI</title>
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    <description>Reassessment was challenged on the validity of the AO&#039;s &quot;reasons to believe&quot; under the live-link standard. The recorded reasons contained internal contradictions: the AO stated the assessee had not filed a return for the year, yet also asserted that the &quot;income declared&quot; did not match cash deposits, showing uncertainty on a foundational fact; consequently, the belief was not based on coherent, reliable premises and reassessment was invalidated. The AO further relied solely on AIR cash-deposit information without any independent analysis or tangible material connecting the deposits to undisclosed income, rendering the reasons vague and lacking a rational nexus; accordingly, the assessee&#039;s ground was allowed and the reassessment was quashed.</description>
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    <pubDate>Fri, 19 Dec 2025 00:00:00 +0530</pubDate>
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      <title>2026 (1) TMI 125 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=784369</link>
      <description>Reassessment was challenged on the validity of the AO&#039;s &quot;reasons to believe&quot; under the live-link standard. The recorded reasons contained internal contradictions: the AO stated the assessee had not filed a return for the year, yet also asserted that the &quot;income declared&quot; did not match cash deposits, showing uncertainty on a foundational fact; consequently, the belief was not based on coherent, reliable premises and reassessment was invalidated. The AO further relied solely on AIR cash-deposit information without any independent analysis or tangible material connecting the deposits to undisclosed income, rendering the reasons vague and lacking a rational nexus; accordingly, the assessee&#039;s ground was allowed and the reassessment was quashed.</description>
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      <pubDate>Fri, 19 Dec 2025 00:00:00 +0530</pubDate>
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