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    <title>2026 (3) TMI 1550 - ITAT AHMEDABAD</title>
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    <description>Reopening under section 147 was upheld where the Assessing Officer relied on Investigation Wing information, bank account analysis, field enquiry, cancellation of VAT registration and a sworn statement linking the assessee to alleged paper concerns issuing accommodation entries. The Tribunal found that the reasons recorded showed application of mind before notice under section 148, and the objections were duly considered. It held that the reopening was supported by tangible material, not borrowed satisfaction or mere suspicion, and that a rational connection and live link existed between the material and the belief that income had escaped assessment. The jurisdictional challenge was therefore rejected.</description>
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      <title>2026 (3) TMI 1550 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=788795</link>
      <description>Reopening under section 147 was upheld where the Assessing Officer relied on Investigation Wing information, bank account analysis, field enquiry, cancellation of VAT registration and a sworn statement linking the assessee to alleged paper concerns issuing accommodation entries. The Tribunal found that the reasons recorded showed application of mind before notice under section 148, and the objections were duly considered. It held that the reopening was supported by tangible material, not borrowed satisfaction or mere suspicion, and that a rational connection and live link existed between the material and the belief that income had escaped assessment. The jurisdictional challenge was therefore rejected.</description>
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