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    <title>2026 (5) TMI 1267 - ITAT DELHI</title>
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    <description>Reassessment under section 147 must remain confined to the reasons recorded for reopening, and the Assessing Officer cannot sustain additions on issues outside that jurisdictional basis. Where the recorded reasons referred to accommodation entries from specified entities but the assessment made additions for transactions with different entities not mentioned in those reasons, the reassessment exceeded the permissible scope. The addition on matters not covered by the recorded reasons was therefore unsustainable and was deleted in favour of the assessee.</description>
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      <description>Reassessment under section 147 must remain confined to the reasons recorded for reopening, and the Assessing Officer cannot sustain additions on issues outside that jurisdictional basis. Where the recorded reasons referred to accommodation entries from specified entities but the assessment made additions for transactions with different entities not mentioned in those reasons, the reassessment exceeded the permissible scope. The addition on matters not covered by the recorded reasons was therefore unsustainable and was deleted in favour of the assessee.</description>
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