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    <title>2026 (4) TMI 903 - ITAT KOLKATA</title>
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    <description>Timely issue of a reassessment notice under the Income-tax Act, 1961 was treated as distinct from its service: where notice is issued within limitation, jurisdiction to reopen is not defeated merely because service is alleged after the cut-off date. On the share-sale receipts added as unexplained cash credit, the Tribunal noted inadequate verification material, including missing purchase, sale, PAN and address details, but also held that the assessee should get a fresh opportunity. The matter was therefore remanded for de novo examination with liberty to draw an adverse inference if supporting evidence is not produced.</description>
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      <link>https://www.taxtmi.com/caselaws?id=789834</link>
      <description>Timely issue of a reassessment notice under the Income-tax Act, 1961 was treated as distinct from its service: where notice is issued within limitation, jurisdiction to reopen is not defeated merely because service is alleged after the cut-off date. On the share-sale receipts added as unexplained cash credit, the Tribunal noted inadequate verification material, including missing purchase, sale, PAN and address details, but also held that the assessee should get a fresh opportunity. The matter was therefore remanded for de novo examination with liberty to draw an adverse inference if supporting evidence is not produced.</description>
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