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    <title>2026 (4) TMI 745 - GUJARAT HIGH COURT</title>
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    <description>Reassessment under the Income-tax Act cannot rest on material lacking a direct and rational nexus with the assessee. An undated complaint and a cash receipt image recovered from the device of an unrelated person, without any connection to the assessee or the searched entities, were held insufficient to support reasons to believe escapement of income. The reopening was also undermined because the complaint was never investigated and its author was not summoned, leaving the material unverified. On these facts, the notices under Section 148A(1), the order under Section 148A(3), and the consequential notice under Section 148 were unsustainable and were quashed.</description>
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      <description>Reassessment under the Income-tax Act cannot rest on material lacking a direct and rational nexus with the assessee. An undated complaint and a cash receipt image recovered from the device of an unrelated person, without any connection to the assessee or the searched entities, were held insufficient to support reasons to believe escapement of income. The reopening was also undermined because the complaint was never investigated and its author was not summoned, leaving the material unverified. On these facts, the notices under Section 148A(1), the order under Section 148A(3), and the consequential notice under Section 148 were unsustainable and were quashed.</description>
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