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    <title>2026 (5) TMI 1762 - ITAT AGRA</title>
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    <description>Reassessment based only on third-party information was held unsustainable where the notice under section 148 was issued beyond six years from the end of the assessment year and no independent material showed failure to disclose material facts. The accompanying addition for alleged accommodation entry also could not be sustained when the amount had already been disclosed in the return and reflected in the books, leaving no valid basis to treat it as unexplained money under section 69A or to apply section 115BBE. The reassessment and related addition were therefore set aside, granting relief to the assessee.</description>
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      <link>https://www.taxtmi.com/caselaws?id=792559</link>
      <description>Reassessment based only on third-party information was held unsustainable where the notice under section 148 was issued beyond six years from the end of the assessment year and no independent material showed failure to disclose material facts. The accompanying addition for alleged accommodation entry also could not be sustained when the amount had already been disclosed in the return and reflected in the books, leaving no valid basis to treat it as unexplained money under section 69A or to apply section 115BBE. The reassessment and related addition were therefore set aside, granting relief to the assessee.</description>
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