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    <title>2026 (4) TMI 741 - GUJARAT HIGH COURT</title>
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    <description>Reopening under the Income-tax Act cannot rest on unverified material lacking a direct nexus with the assessee. The High Court found that the undated complaint said to have emerged from digital data in a survey on an unrelated entity was not independently examined, its author was not summoned, and the relied-upon statements and cash-receipt image did not establish receipt of cash by the assessee or a family member. In the absence of a verified factual foundation linking the material to the assessee, the reassessment initiation was treated as conjectural, and the notices under sections 148A(1) and 148, together with the order under section 148A(3), were quashed.</description>
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      <description>Reopening under the Income-tax Act cannot rest on unverified material lacking a direct nexus with the assessee. The High Court found that the undated complaint said to have emerged from digital data in a survey on an unrelated entity was not independently examined, its author was not summoned, and the relied-upon statements and cash-receipt image did not establish receipt of cash by the assessee or a family member. In the absence of a verified factual foundation linking the material to the assessee, the reassessment initiation was treated as conjectural, and the notices under sections 148A(1) and 148, together with the order under section 148A(3), were quashed.</description>
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