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    <title>2026 (3) TMI 1406 - ITAT AHMEDABAD</title>
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    <description>Tangible information from the Investigation Wing regarding substantial cash deposits provided a valid basis for reopening, so the challenge to reassessment under sections 147 and 148 failed. However, where the assessee could not prove the source or identity behind the deposits and the bank account showed immediate withdrawals after deposits, taxing the entire cash inflow was considered excessive. The addition was therefore restricted to the peak balance of the account, reflecting rotation of funds rather than a one-time unexplained accretion. The reopening was upheld, but the substantive addition was confined to the peak credit approach, granting partial relief.</description>
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      <title>2026 (3) TMI 1406 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=788651</link>
      <description>Tangible information from the Investigation Wing regarding substantial cash deposits provided a valid basis for reopening, so the challenge to reassessment under sections 147 and 148 failed. However, where the assessee could not prove the source or identity behind the deposits and the bank account showed immediate withdrawals after deposits, taxing the entire cash inflow was considered excessive. The addition was therefore restricted to the peak balance of the account, reflecting rotation of funds rather than a one-time unexplained accretion. The reopening was upheld, but the substantive addition was confined to the peak credit approach, granting partial relief.</description>
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      <pubDate>Tue, 24 Mar 2026 00:00:00 +0530</pubDate>
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