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    <title>2026 (6) TMI 40 - ITAT PUNE</title>
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    <description>Reassessment challenges based on alleged lack of administrative approval, defective reopening satisfaction, and extended limitation were rejected because the approval process and statutory preconditions under sections 149 and 151 were found satisfied. The seized handwritten cash books and digital data, including material linked from third-party premises, were treated as usable against the assessee group in light of statements, admissions, and corroborative records, and objections based on retraction and ownership of premises were not accepted as grounds for total exclusion. For tax computation, the entries were held to represent a single rotating cash pool, so gross additions on on-money receipts and separate additions for V A/c entries were unsustainable. The correct method was a unified peak credit computation with carry-forward of the earlier peak.</description>
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      <link>https://www.taxtmi.com/caselaws?id=792659</link>
      <description>Reassessment challenges based on alleged lack of administrative approval, defective reopening satisfaction, and extended limitation were rejected because the approval process and statutory preconditions under sections 149 and 151 were found satisfied. The seized handwritten cash books and digital data, including material linked from third-party premises, were treated as usable against the assessee group in light of statements, admissions, and corroborative records, and objections based on retraction and ownership of premises were not accepted as grounds for total exclusion. For tax computation, the entries were held to represent a single rotating cash pool, so gross additions on on-money receipts and separate additions for V A/c entries were unsustainable. The correct method was a unified peak credit computation with carry-forward of the earlier peak.</description>
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