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    <title>2026 (6) TMI 1089 - BOMBAY HIGH COURT</title>
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    <description>A reassessment notice under section 148 must be based on a subsisting and legally sustainable reason to believe. On the first point, the assessee had received only the gist of the recorded reasons, not the full reasons, but the reassessment was not faulted on that ground. On the second point, the sole basis for the reopening was a statement by a director that had already been retracted before the notice was issued, and that retraction had been accepted in appellate proceedings. The foundation for belief of escapement was therefore absent, and the notice was unsustainable. The Tribunal&#039;s order was upheld and the Revenue&#039;s appeal was dismissed.</description>
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      <title>2026 (6) TMI 1089 - BOMBAY HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=793708</link>
      <description>A reassessment notice under section 148 must be based on a subsisting and legally sustainable reason to believe. On the first point, the assessee had received only the gist of the recorded reasons, not the full reasons, but the reassessment was not faulted on that ground. On the second point, the sole basis for the reopening was a statement by a director that had already been retracted before the notice was issued, and that retraction had been accepted in appellate proceedings. The foundation for belief of escapement was therefore absent, and the notice was unsustainable. The Tribunal&#039;s order was upheld and the Revenue&#039;s appeal was dismissed.</description>
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