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    <title>Reopening of assessment invalid where mandatory conditions for notices beyond three years are not satisfied, notice quashed.</title>
    <link>https://www.taxtmi.com/highlights?id=97158</link>
    <description>Reopening of assessment under notice u/s.148 was invalid because the AO did not satisfy the mandatory conditions for issuing a notice beyond three years, and the reasons failed to establish escaped income exceeding the statutory threshold tied to assets/expenditure or book entries; outcome: notice and consequent assessment quashed. Approval by the prescribed authority under the sanction provision was held mechanical and without independent verification of seized material, lacking application of mind; outcome: sanction invalidated and reinforcement of notice invalidity. Search-origin evidence seized from a third party laptop was not treated as sufficient to justify reopening when statutory conditions were unmet.</description>
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    <pubDate>Wed, 25 Feb 2026 11:52:38 +0530</pubDate>
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      <title>Reopening of assessment invalid where mandatory conditions for notices beyond three years are not satisfied, notice quashed.</title>
      <link>https://www.taxtmi.com/highlights?id=97158</link>
      <description>Reopening of assessment under notice u/s.148 was invalid because the AO did not satisfy the mandatory conditions for issuing a notice beyond three years, and the reasons failed to establish escaped income exceeding the statutory threshold tied to assets/expenditure or book entries; outcome: notice and consequent assessment quashed. Approval by the prescribed authority under the sanction provision was held mechanical and without independent verification of seized material, lacking application of mind; outcome: sanction invalidated and reinforcement of notice invalidity. Search-origin evidence seized from a third party laptop was not treated as sufficient to justify reopening when statutory conditions were unmet.</description>
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      <pubDate>Wed, 25 Feb 2026 11:52:38 +0530</pubDate>
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