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    <title>2026 (4) TMI 823 - ITAT AHMEDABAD</title>
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    <description>Reassessment is invalid where the reasons recorded for reopening concern alleged fictitious loans, but the final addition is made on a materially different basis, such as alleged bogus long-term capital gain from penny stock transactions. The recorded belief must correspond to the income ultimately brought to tax, and a reassessment cannot be sustained when the foundation for reopening and the basis of the assessment diverge. On this ground, the reassessment was held legally infirm and the reassessment order was quashed in favour of the assessee.</description>
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      <description>Reassessment is invalid where the reasons recorded for reopening concern alleged fictitious loans, but the final addition is made on a materially different basis, such as alleged bogus long-term capital gain from penny stock transactions. The recorded belief must correspond to the income ultimately brought to tax, and a reassessment cannot be sustained when the foundation for reopening and the basis of the assessment diverge. On this ground, the reassessment was held legally infirm and the reassessment order was quashed in favour of the assessee.</description>
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