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    <title>2026 (2) TMI 449 - ITAT DELHI</title>
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    <description>Addition for non genuine accommodation entries was treated as unexplained money and deleted because the assessing officer relied on statements and investigative inputs without sufficient basis; consequence: addition under unexplained money was overturned. Reopening of assessment was invalidated for being based solely on an Investigation Wing report without independent application of mind (borrowed satisfaction); consequence: reassessment proceedings quashed. Reopening beyond four years failed because the assessee had fully and truly disclosed material facts at original assessment, so the proviso precondition for extended reassessment was not satisfied; consequence: reassessment could not be sustained.</description>
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      <link>https://www.taxtmi.com/caselaws?id=786254</link>
      <description>Addition for non genuine accommodation entries was treated as unexplained money and deleted because the assessing officer relied on statements and investigative inputs without sufficient basis; consequence: addition under unexplained money was overturned. Reopening of assessment was invalidated for being based solely on an Investigation Wing report without independent application of mind (borrowed satisfaction); consequence: reassessment proceedings quashed. Reopening beyond four years failed because the assessee had fully and truly disclosed material facts at original assessment, so the proviso precondition for extended reassessment was not satisfied; consequence: reassessment could not be sustained.</description>
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