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    <title>2026 (5) TMI 97 - ITAT DELHI</title>
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    <description>Reassessment notice issued beyond three years was held invalid because approval was taken from the wrong sanctioning authority under section 151(ii), so the reassessment failed. Additions for alleged cash sales through dummy buyers, commission payments, and suppression of gross profit were deleted because the record contained books, invoices, GST and banking trail, while suspicion and non-response of buyers did not prove unaccounted cash or commission outgo. The Assessing Officer could not replace the assessee&#039;s DCF share valuation with NAV under section 56(2)(viib) absent a demonstrable defect in the chosen rule-based method, so the addition was deleted. Cash-related additions were partly remanded for reconciliation, and cash with a third person was confined to the possible profit element.</description>
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    <pubDate>Wed, 29 Apr 2026 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=790895</link>
      <description>Reassessment notice issued beyond three years was held invalid because approval was taken from the wrong sanctioning authority under section 151(ii), so the reassessment failed. Additions for alleged cash sales through dummy buyers, commission payments, and suppression of gross profit were deleted because the record contained books, invoices, GST and banking trail, while suspicion and non-response of buyers did not prove unaccounted cash or commission outgo. The Assessing Officer could not replace the assessee&#039;s DCF share valuation with NAV under section 56(2)(viib) absent a demonstrable defect in the chosen rule-based method, so the addition was deleted. Cash-related additions were partly remanded for reconciliation, and cash with a third person was confined to the possible profit element.</description>
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