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    <title>2026 (2) TMI 488 - ITAT AHMEDABAD</title>
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    <description>Reopening of assessment under section 147 was challenged on grounds that the assessing officer failed to apply independent mind because the reasons for reopening were verbatim identical to those used for related entities; reliance was placed on earlier tribunal findings showing identical search reasons. The searched person corroborated the recorded expenditures and departmental appeals in linked matters were dismissed, undermining the bogus purchase allegation. For these reasons the Tribunal found the reopening unsupported by independent reasons and permitted the assessee&#039;s appeal, resulting in the restoration of the assessment position in favour of the assessee.</description>
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    <pubDate>Tue, 06 Jan 2026 00:00:00 +0530</pubDate>
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      <title>2026 (2) TMI 488 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=786340</link>
      <description>Reopening of assessment under section 147 was challenged on grounds that the assessing officer failed to apply independent mind because the reasons for reopening were verbatim identical to those used for related entities; reliance was placed on earlier tribunal findings showing identical search reasons. The searched person corroborated the recorded expenditures and departmental appeals in linked matters were dismissed, undermining the bogus purchase allegation. For these reasons the Tribunal found the reopening unsupported by independent reasons and permitted the assessee&#039;s appeal, resulting in the restoration of the assessment position in favour of the assessee.</description>
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