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    <title>2026 (5) TMI 410 - ITAT MUMBAI</title>
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    <description>Reassessment under section 147 was held invalid where the reopening was based only on balance sheet, profit and loss account, and other material already examined in the completed scrutiny assessment. As no fresh or tangible material came to the Assessing Officer after the original section 143(3) assessment, the belief that income had escaped assessment was treated as a mere reappraisal of existing records and suspicion, which was insufficient to satisfy the jurisdictional requirement of a valid reason to believe. The reassessment notice and resulting assessment order were quashed in favour of the assessee.</description>
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      <title>2026 (5) TMI 410 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=791208</link>
      <description>Reassessment under section 147 was held invalid where the reopening was based only on balance sheet, profit and loss account, and other material already examined in the completed scrutiny assessment. As no fresh or tangible material came to the Assessing Officer after the original section 143(3) assessment, the belief that income had escaped assessment was treated as a mere reappraisal of existing records and suspicion, which was insufficient to satisfy the jurisdictional requirement of a valid reason to believe. The reassessment notice and resulting assessment order were quashed in favour of the assessee.</description>
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