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    <title>2025 (9) TMI 1783 - GUJARAT HIGH COURT</title>
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    <description>Reassessment under Section 148 was held unsustainable where the recorded reasons named the wrong entity, did not connect the assessee to the seized material, and relied on a generalized inference rather than independent consideration of the assessee&#039;s transaction. The assessee&#039;s explanation that the amount represented commission payment, supported by TDS deduction and service tax payment, was not met by any contrary material. The rejection of objections under Section 148A(d) therefore lacked the required nexus between tangible material and the formation of belief that income had escaped assessment, and the notice and consequential order were quashed.</description>
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      <title>2025 (9) TMI 1783 - GUJARAT HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=468328</link>
      <description>Reassessment under Section 148 was held unsustainable where the recorded reasons named the wrong entity, did not connect the assessee to the seized material, and relied on a generalized inference rather than independent consideration of the assessee&#039;s transaction. The assessee&#039;s explanation that the amount represented commission payment, supported by TDS deduction and service tax payment, was not met by any contrary material. The rejection of objections under Section 148A(d) therefore lacked the required nexus between tangible material and the formation of belief that income had escaped assessment, and the notice and consequential order were quashed.</description>
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