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    <title>2026 (1) TMI 601 - ITAT KOLKATA</title>
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    <description>Reopening of assessment was quashed because the assessing officer relied on information from investigation without recording independent, specific reasons to believe; reopening based on borrowed satisfaction and vague reasons was held invalid, and the appellate order quashing reopening was upheld. Regarding additions as unexplained cash credits alleged under the share capital head, the assessee produced subscriber details, bank statements and audited accounts and no material defect was shown by the assessing officer; absence of replies from some subscribers and summons non-response was held insufficient to justify addition, and the amendment proviso to the applicable provision was held not to apply retrospectively, resulting in dismissal of the revenue&#039;s grounds.</description>
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    <pubDate>Tue, 23 Dec 2025 00:00:00 +0530</pubDate>
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      <title>2026 (1) TMI 601 - ITAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=784845</link>
      <description>Reopening of assessment was quashed because the assessing officer relied on information from investigation without recording independent, specific reasons to believe; reopening based on borrowed satisfaction and vague reasons was held invalid, and the appellate order quashing reopening was upheld. Regarding additions as unexplained cash credits alleged under the share capital head, the assessee produced subscriber details, bank statements and audited accounts and no material defect was shown by the assessing officer; absence of replies from some subscribers and summons non-response was held insufficient to justify addition, and the amendment proviso to the applicable provision was held not to apply retrospectively, resulting in dismissal of the revenue&#039;s grounds.</description>
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