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    <title>2026 (6) TMI 1127 - ITAT RAJKOT</title>
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    <description>Reassessment under the Income-tax Act was treated as invalid where the recorded reasons for reopening were vague, factually incorrect, and unsupported by tangible material. The ITAT noted the absence of a date, clear property details, identification of the buyer, verification of the sale deed, and proper quantification of escapement, so no live nexus existed between the material and the belief that income had escaped assessment. The sanction under section 151 was also found unsustainable because the reopening, being beyond four years, required informed approval with due application of mind. The reassessment proceedings were quashed, and the consequential assessment became academic.</description>
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      <link>https://www.taxtmi.com/caselaws?id=793746</link>
      <description>Reassessment under the Income-tax Act was treated as invalid where the recorded reasons for reopening were vague, factually incorrect, and unsupported by tangible material. The ITAT noted the absence of a date, clear property details, identification of the buyer, verification of the sale deed, and proper quantification of escapement, so no live nexus existed between the material and the belief that income had escaped assessment. The sanction under section 151 was also found unsustainable because the reopening, being beyond four years, required informed approval with due application of mind. The reassessment proceedings were quashed, and the consequential assessment became academic.</description>
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