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    <title>2026 (1) TMI 1633 - ITAT DELHI</title>
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    <description>Reassessment under Sections 147 and 148 was held invalid where the recorded reasons merely reproduced Investigation Wing information without independent verification or examination of the seized material. The reopening was based on vague references to accommodation entries and did not identify the precise alleged transaction or explain how income had escaped assessment. The sanction under Section 151 was also found to be mechanical, as the approving authority gave only a bare endorsement without meaningful consideration of the reasons. On these facts, the reassessment proceedings were quashed and the additions made therein could not be sustained.</description>
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    <pubDate>Wed, 14 Jan 2026 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=469118</link>
      <description>Reassessment under Sections 147 and 148 was held invalid where the recorded reasons merely reproduced Investigation Wing information without independent verification or examination of the seized material. The reopening was based on vague references to accommodation entries and did not identify the precise alleged transaction or explain how income had escaped assessment. The sanction under Section 151 was also found to be mechanical, as the approving authority gave only a bare endorsement without meaningful consideration of the reasons. On these facts, the reassessment proceedings were quashed and the additions made therein could not be sustained.</description>
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      <pubDate>Wed, 14 Jan 2026 00:00:00 +0530</pubDate>
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