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    <description>Reassessment is valid where the recorded reasons are based on specific tangible information and show a live link to the belief that income has escaped assessment; an inadvertent wrong reference to the earlier assessment stage does not by itself vitiate the reopening. On merits, an addition cannot be sustained without cogent material proving that the assessee actually received the alleged accommodation entry, and a consistent denial remains effective if unrebutted by evidence. The reopening was upheld, but the impugned addition was deleted, giving the assessee partial relief.</description>
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      <description>Reassessment is valid where the recorded reasons are based on specific tangible information and show a live link to the belief that income has escaped assessment; an inadvertent wrong reference to the earlier assessment stage does not by itself vitiate the reopening. On merits, an addition cannot be sustained without cogent material proving that the assessee actually received the alleged accommodation entry, and a consistent denial remains effective if unrebutted by evidence. The reopening was upheld, but the impugned addition was deleted, giving the assessee partial relief.</description>
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