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    <title>2026 (4) TMI 1698 - ITAT AHMEDABAD</title>
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    <description>Reassessment under section 147 must stand or fall on the specific escapement reason recorded for reopening, and the Assessing Officer cannot sustain jurisdiction by making an addition on an unrecorded issue. Here, the reopening was based on an alleged accommodation entry from one concern, but no addition was made on that recorded ground in the assessment order; the only addition related to a different concern not mentioned in the reasons. On these facts, the reassessment lacked a valid jurisdictional foundation and was quashed, with the assessee&#039;s appeal succeeding.</description>
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      <title>2026 (4) TMI 1698 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=790629</link>
      <description>Reassessment under section 147 must stand or fall on the specific escapement reason recorded for reopening, and the Assessing Officer cannot sustain jurisdiction by making an addition on an unrecorded issue. Here, the reopening was based on an alleged accommodation entry from one concern, but no addition was made on that recorded ground in the assessment order; the only addition related to a different concern not mentioned in the reasons. On these facts, the reassessment lacked a valid jurisdictional foundation and was quashed, with the assessee&#039;s appeal succeeding.</description>
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      <pubDate>Fri, 24 Apr 2026 00:00:00 +0530</pubDate>
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