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    <title>2026 (5) TMI 104 - ITAT DELHI</title>
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    <description>Reopening of assessment under sections 147 and 148 based on identical reasons alleging undisclosed commission income from accommodation entries was unsustainable because the recorded material did not show direct evidence of actual commission income. Statements recorded during search, without corroborative tangible material, were insufficient, and the reasons for reopening had to stand on their own without later supplementation. The reassessment initiation was therefore treated as resting on conjecture and surmise rather than legally sustainable material, and the reopening was quashed in favour of the assessee.</description>
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    <pubDate>Thu, 30 Apr 2026 00:00:00 +0530</pubDate>
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      <title>2026 (5) TMI 104 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=790902</link>
      <description>Reopening of assessment under sections 147 and 148 based on identical reasons alleging undisclosed commission income from accommodation entries was unsustainable because the recorded material did not show direct evidence of actual commission income. Statements recorded during search, without corroborative tangible material, were insufficient, and the reasons for reopening had to stand on their own without later supplementation. The reassessment initiation was therefore treated as resting on conjecture and surmise rather than legally sustainable material, and the reopening was quashed in favour of the assessee.</description>
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      <pubDate>Thu, 30 Apr 2026 00:00:00 +0530</pubDate>
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