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    <title>2026 (3) TMI 1473 - ITAT HYDERABAD</title>
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    <description>Reassessment under sections 147 and 148 was invalid because the recorded reasons rested on third-party information about alleged reversal trades in illiquid stock options, while the assessee&#039;s original scrutiny assessment under section 143(3) reflected disclosed income from currency derivative transactions. The material was not independently matched with the assessee&#039;s record, and the reasons were treated as borrowed satisfaction without application of mind. As there was no live link between the information and a bona fide belief of escapement of income, and the relevant profit had already been disclosed, the statutory conditions for reopening after scrutiny were not met. The reopening was quashed.</description>
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      <title>2026 (3) TMI 1473 - ITAT HYDERABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=788718</link>
      <description>Reassessment under sections 147 and 148 was invalid because the recorded reasons rested on third-party information about alleged reversal trades in illiquid stock options, while the assessee&#039;s original scrutiny assessment under section 143(3) reflected disclosed income from currency derivative transactions. The material was not independently matched with the assessee&#039;s record, and the reasons were treated as borrowed satisfaction without application of mind. As there was no live link between the information and a bona fide belief of escapement of income, and the relevant profit had already been disclosed, the statutory conditions for reopening after scrutiny were not met. The reopening was quashed.</description>
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