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    <title>2026 (4) TMI 772 - ITAT NAGPUR</title>
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    <description>Reassessment requires an independently formed belief on relevant material, not borrowed satisfaction or unverified information; on these facts, the notice and reassessment order were invalid because the assessee had produced invoices, bank records, transport documents, e-way bills, GST returns and stock details, and the adverse material was not properly supplied or dealt with. The addition for alleged bogus purchases under section 69C also failed because the purchases were recorded, payments were through banking channels, sales were not disputed, the books were not rejected, and the source of expenditure was explained by documentary evidence. The consequential levy under section 115BBE was therefore unsustainable, and the assessment was annulled.</description>
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      <description>Reassessment requires an independently formed belief on relevant material, not borrowed satisfaction or unverified information; on these facts, the notice and reassessment order were invalid because the assessee had produced invoices, bank records, transport documents, e-way bills, GST returns and stock details, and the adverse material was not properly supplied or dealt with. The addition for alleged bogus purchases under section 69C also failed because the purchases were recorded, payments were through banking channels, sales were not disputed, the books were not rejected, and the source of expenditure was explained by documentary evidence. The consequential levy under section 115BBE was therefore unsustainable, and the assessment was annulled.</description>
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