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    <title>2026 (1) TMI 1190 - ITAT AHMEDABAD</title>
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    <description>Validity of reopening of assessment centred on whether reasons recorded justified treating long term capital gain as unexplained credit; tribunal found the recorded reasons incorrect and held that continuation of reopened proceedings to make additions on grounds not forming part of the reasons was impermissible, citing precedent that absence of additions on original grounds precludes new additions on different grounds. The consequence was that the additions made beyond the recorded reasons were illegal and beyond jurisdiction, the assessment order was quashed, and the assessee&#039;s appeal allowed; AO retained power to reopen afresh if genuine further material emerged and was recorded.</description>
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      <link>https://www.taxtmi.com/caselaws?id=785434</link>
      <description>Validity of reopening of assessment centred on whether reasons recorded justified treating long term capital gain as unexplained credit; tribunal found the recorded reasons incorrect and held that continuation of reopened proceedings to make additions on grounds not forming part of the reasons was impermissible, citing precedent that absence of additions on original grounds precludes new additions on different grounds. The consequence was that the additions made beyond the recorded reasons were illegal and beyond jurisdiction, the assessment order was quashed, and the assessee&#039;s appeal allowed; AO retained power to reopen afresh if genuine further material emerged and was recorded.</description>
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