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    <title>2026 (6) TMI 361 - ITAT SURAT</title>
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    <description>A purely legal jurisdictional ground may be raised for the first time before the Tribunal when all relevant facts are already on record, so the additional challenge to reassessment was admitted. Reassessment is not sustainable where the assessment is completed on an issue different from the recorded reasons for reopening; here, the reopening was based on alleged escapement from time deposit investment and interest income, but the addition was made on long-term capital gain from sale of agricultural land. In the absence of fresh recorded reasons or lawful expansion of the reopening, the reassessment was void ab initio and the addition could not survive.</description>
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