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    <title>2026 (6) TMI 1048 - GUJARAT HIGH COURT</title>
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    <description>Reopening based on high-value bank transactions was held unsustainable where the credits and debits were recorded in the books, the audited accounts reflected the transactions, and the fund providers were regular return filers. Mere transaction volume, absence of an NBFC licence, and non-charging of interest did not by themselves show escapement of income. The M2M loss allegation could not be relied on because it was not put to the assessee in the notice, and the bullion allegation lacked supporting material. The reassessment notices and the related orders were quashed.</description>
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      <description>Reopening based on high-value bank transactions was held unsustainable where the credits and debits were recorded in the books, the audited accounts reflected the transactions, and the fund providers were regular return filers. Mere transaction volume, absence of an NBFC licence, and non-charging of interest did not by themselves show escapement of income. The M2M loss allegation could not be relied on because it was not put to the assessee in the notice, and the bullion allegation lacked supporting material. The reassessment notices and the related orders were quashed.</description>
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