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    <title>2026 (3) TMI 873 - ITAT AHMEDABAD</title>
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    <description>Reopening of assessment was upheld where the Assessing Officer received specific information of substantial cash receipts, examined available material and recorded reasons forming a prima facie belief of escapement; information from another wing suffices only if the AO applies his own independent mind, so reopening was not a roving enquiry or borrowed satisfaction. Separately, an addition as unexplained investment was sustained because the assessee failed to produce contemporaneous or independent evidence to substantiate claimed sources (opening cash, trading receipts, agricultural and milk income), and thus did not discharge the onus, justifying the addition.</description>
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