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    <title>2026 (4) TMI 1690 - ITAT CHANDIGARH</title>
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    <description>A search after 1 April 2021 brought the relevant year within the reassessment framework under the deeming fiction in Explanation 2 to section 148, so the assessment had to follow sections 147 and 148 with the required approvals and could not be completed as a regular scrutiny assessment under section 143(3). On merits, an addition for undervalued fresh allotment of shares under section 56(2)(x)(c) was deleted because the transaction did not fall within the charging provision. A cash payment addition under section 69C was sustained on seized material, the bogus-purchase disallowance was confined to the incriminating entries, and the interest disallowance under section 36(1)(iii) was deleted on availability of interest-free funds.</description>
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      <description>A search after 1 April 2021 brought the relevant year within the reassessment framework under the deeming fiction in Explanation 2 to section 148, so the assessment had to follow sections 147 and 148 with the required approvals and could not be completed as a regular scrutiny assessment under section 143(3). On merits, an addition for undervalued fresh allotment of shares under section 56(2)(x)(c) was deleted because the transaction did not fall within the charging provision. A cash payment addition under section 69C was sustained on seized material, the bogus-purchase disallowance was confined to the incriminating entries, and the interest disallowance under section 36(1)(iii) was deleted on availability of interest-free funds.</description>
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