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    <title>Alleged bogus sales and purchases trigger reassessment u/ss147/148A, but reopening and 2% commission/purchase disallowance quashed</title>
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    <description>Reassessment proceedings under ss. 147/148A were held invalid as the AO acted on borrowed satisfaction by mechanically reproducing a general investigation report without verifying accuracy, clarifying whether the alleged dealings were purchases or sales, or establishing a direct, tangible, live nexus between the material and escapement of income; factual errors in the alleged transaction quantum further showed absence of independent &quot;reason to believe&quot;, resulting in quashing of reopening. The estimated 2% commission addition on alleged bogus sales was deleted since sales were recorded, supported by documents and statutory filings, and no evidence of accommodation entries, cash flow, or benefit was found. Disallowance of alleged bogus purcha.....</description>
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    <pubDate>Sat, 10 Jan 2026 08:25:22 +0530</pubDate>
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      <title>Alleged bogus sales and purchases trigger reassessment u/ss147/148A, but reopening and 2% commission/purchase disallowance quashed</title>
      <link>https://www.taxtmi.com/highlights?id=95911</link>
      <description>Reassessment proceedings under ss. 147/148A were held invalid as the AO acted on borrowed satisfaction by mechanically reproducing a general investigation report without verifying accuracy, clarifying whether the alleged dealings were purchases or sales, or establishing a direct, tangible, live nexus between the material and escapement of income; factual errors in the alleged transaction quantum further showed absence of independent &quot;reason to believe&quot;, resulting in quashing of reopening. The estimated 2% commission addition on alleged bogus sales was deleted since sales were recorded, supported by documents and statutory filings, and no evidence of accommodation entries, cash flow, or benefit was found. Disallowance of alleged bogus purcha.....</description>
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