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    <description>Reassessment under the Income-tax Act requires recorded reasons to be clear, supported by material, and linked by a live nexus to the alleged escapement of income. Where the reopening was based on survey information but the material did not show that the receipt was anything other than dividend, and the reasons shifted between exempt dividend and fictitious short-term capital loss, the court treated the reopening as unsupported and inconsistent. On that basis, the reassessment order under Section 148A(d) and the consequential notice under Section 148 were quashed for non-application of mind and arbitrariness.</description>
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