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    <title>2026 (2) TMI 366 - ITAT DELHI</title>
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    <description>Reopening an assessment under section 147 solely because an assessee reported a low net profit rate was held invalid where the assessing officer lacked a live nexus between tangible material on record and the recorded reasons. The tribunal found estimating income by applying a higher presumptive net profit percentage was unsupported, noting that the appellate authority&#039;s reliance on a prior year figure was undermined by the ITAT&#039;s subsequent deletion of that addition in the earlier year. Consequence: the reassessment was quashed and decision given in favour of the assessee.</description>
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      <link>https://www.taxtmi.com/caselaws?id=786171</link>
      <description>Reopening an assessment under section 147 solely because an assessee reported a low net profit rate was held invalid where the assessing officer lacked a live nexus between tangible material on record and the recorded reasons. The tribunal found estimating income by applying a higher presumptive net profit percentage was unsupported, noting that the appellate authority&#039;s reliance on a prior year figure was undermined by the ITAT&#039;s subsequent deletion of that addition in the earlier year. Consequence: the reassessment was quashed and decision given in favour of the assessee.</description>
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