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    <title>2026 (5) TMI 393 - ITAT AHMEDABAD</title>
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    <description>Reassessment under section 147 was invalid where the recorded material did not establish a live nexus between the information before the Assessing Officer and a bona fide reason to believe that income had escaped assessment for the relevant year. Suspicion based on subsequent-year assessment, cash deposits and property transactions was insufficient, and mere inadequacy of returned income to explain investments or deposits did not meet the statutory threshold without further enquiry. Explanation 2(b) to section 147 was also inapplicable because there was no recorded finding of understatement of income within its scope. The reassessment was therefore without jurisdiction and the assessment was quashed.</description>
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    <pubDate>Thu, 16 Apr 2026 00:00:00 +0530</pubDate>
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      <title>2026 (5) TMI 393 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=791191</link>
      <description>Reassessment under section 147 was invalid where the recorded material did not establish a live nexus between the information before the Assessing Officer and a bona fide reason to believe that income had escaped assessment for the relevant year. Suspicion based on subsequent-year assessment, cash deposits and property transactions was insufficient, and mere inadequacy of returned income to explain investments or deposits did not meet the statutory threshold without further enquiry. Explanation 2(b) to section 147 was also inapplicable because there was no recorded finding of understatement of income within its scope. The reassessment was therefore without jurisdiction and the assessment was quashed.</description>
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