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    <title>2026 (5) TMI 1200 - ITAT AHMEDABAD</title>
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    <description>Reassessment under the pre-notice procedure was held unsustainable where the assessee received inadequate time to respond, filed a detailed reply with supporting documents, and the authority wrongly recorded that no reply had been filed. The tribunal noted the absence of independent enquiry and application of mind, treating the action as a breach of natural justice and borrowed satisfaction, so the notice under section 148 and consequential assessment were quashed. An addition for unexplained funds was also deleted because the assessee substantiated the source through documentary evidence on identity, creditworthiness, genuineness, repayments and interest, while the Revenue failed to rebut the explanation.</description>
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      <link>https://www.taxtmi.com/caselaws?id=791998</link>
      <description>Reassessment under the pre-notice procedure was held unsustainable where the assessee received inadequate time to respond, filed a detailed reply with supporting documents, and the authority wrongly recorded that no reply had been filed. The tribunal noted the absence of independent enquiry and application of mind, treating the action as a breach of natural justice and borrowed satisfaction, so the notice under section 148 and consequential assessment were quashed. An addition for unexplained funds was also deleted because the assessee substantiated the source through documentary evidence on identity, creditworthiness, genuineness, repayments and interest, while the Revenue failed to rebut the explanation.</description>
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