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    <title>2026 (5) TMI 86 - ITAT RAJKOT</title>
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    <description>Reassessment under section 147 is valid only where the recorded reasons rest on relevant, tangible material with a live link to the assessee&#039;s alleged escapement of income. Here, the reopening was based on penny stock and accommodation-entry information that related to another person, while the assessee&#039;s own return, audit report, computation, and profit and loss account showed no such share transactions or capital gain. Because the recorded reasons did not establish that the assessee had entered the cited transactions and lacked a proper nexus with the assessee&#039;s records, the jurisdictional for reopening was not satisfied. The reassessment was therefore quashed and the additions became academic.</description>
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    <pubDate>Wed, 15 Apr 2026 00:00:00 +0530</pubDate>
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      <title>2026 (5) TMI 86 - ITAT RAJKOT</title>
      <link>https://www.taxtmi.com/caselaws?id=790884</link>
      <description>Reassessment under section 147 is valid only where the recorded reasons rest on relevant, tangible material with a live link to the assessee&#039;s alleged escapement of income. Here, the reopening was based on penny stock and accommodation-entry information that related to another person, while the assessee&#039;s own return, audit report, computation, and profit and loss account showed no such share transactions or capital gain. Because the recorded reasons did not establish that the assessee had entered the cited transactions and lacked a proper nexus with the assessee&#039;s records, the jurisdictional for reopening was not satisfied. The reassessment was therefore quashed and the additions became academic.</description>
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