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    <title>2026 (5) TMI 395 - ITAT DELHI</title>
    <link>https://www.taxtmi.com/caselaws?id=791193</link>
    <description>Reassessment notices issued after three years require strict satisfaction of section 149(1)(b), including material showing escaped income in the form of an asset, expenditure, or qualifying book entry, and the notices were invalid where only alleged undisclosed receipts and estimated profit were recorded. Notices under section 148 were also defective where they ambiguously failed to identify whether the assessee was the searched person or another person, reflecting non-application of mind, and were invalid. Search-related assessments framed under section 143(3) without following the reassessment route under sections 147 and 148, and without the required approval under section 148B, were unsustainable and were quashed.</description>
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    <pubDate>Fri, 17 Apr 2026 00:00:00 +0530</pubDate>
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      <title>2026 (5) TMI 395 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=791193</link>
      <description>Reassessment notices issued after three years require strict satisfaction of section 149(1)(b), including material showing escaped income in the form of an asset, expenditure, or qualifying book entry, and the notices were invalid where only alleged undisclosed receipts and estimated profit were recorded. Notices under section 148 were also defective where they ambiguously failed to identify whether the assessee was the searched person or another person, reflecting non-application of mind, and were invalid. Search-related assessments framed under section 143(3) without following the reassessment route under sections 147 and 148, and without the required approval under section 148B, were unsustainable and were quashed.</description>
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      <pubDate>Fri, 17 Apr 2026 00:00:00 +0530</pubDate>
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