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    <title>2026 (2) TMI 94 - GUJARAT HIGH COURT</title>
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    <description>Reopening of assessment under Section 147 was challenged on grounds that the only material was a third-party statement which did not refer to the deceased assessee or his debenture investments; the assessee had produced bank records, ledger entries, debenture certificates and financial statements explaining the source of funds. The court found the statement did not constitute tangible material against the deceased and that the revenue neither doubted the source nor identified how the investment constituted escaped taxable income; consequently the jurisdictional precondition for reopening was not met and the notices/orders under Sections 148 and 148A(3) were unsustainable.</description>
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    <pubDate>Thu, 22 Jan 2026 00:00:00 +0530</pubDate>
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      <title>2026 (2) TMI 94 - GUJARAT HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=785899</link>
      <description>Reopening of assessment under Section 147 was challenged on grounds that the only material was a third-party statement which did not refer to the deceased assessee or his debenture investments; the assessee had produced bank records, ledger entries, debenture certificates and financial statements explaining the source of funds. The court found the statement did not constitute tangible material against the deceased and that the revenue neither doubted the source nor identified how the investment constituted escaped taxable income; consequently the jurisdictional precondition for reopening was not met and the notices/orders under Sections 148 and 148A(3) were unsustainable.</description>
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      <pubDate>Thu, 22 Jan 2026 00:00:00 +0530</pubDate>
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