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    <title>2026 (2) TMI 1185 - ITAT AHMEDABAD</title>
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    <description>Reassessment under Section 147/148 was upheld: reasons based on investigative material were supplied and objections did not rebut the material, so borrowed satisfaction and non-disposal contentions fail. Receipts from Orange Tradex were held to reflect conduit/accommodation entries rather than genuine credits; taxability is therefore confined to commission income, not full unexplained credit. The quantum of transfers required verification, and the matter was remitted to the Assessing Officer to determine the correct transaction amount and apply a 2% commission accordingly; appeal partly allowed to that limited extent while revenue&#039;s claim was rejected.</description>
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    <pubDate>Wed, 18 Feb 2026 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=787037</link>
      <description>Reassessment under Section 147/148 was upheld: reasons based on investigative material were supplied and objections did not rebut the material, so borrowed satisfaction and non-disposal contentions fail. Receipts from Orange Tradex were held to reflect conduit/accommodation entries rather than genuine credits; taxability is therefore confined to commission income, not full unexplained credit. The quantum of transfers required verification, and the matter was remitted to the Assessing Officer to determine the correct transaction amount and apply a 2% commission accordingly; appeal partly allowed to that limited extent while revenue&#039;s claim was rejected.</description>
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