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    <title>2026 (6) TMI 1259 - ITAT GUWAHATI</title>
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    <description>Reassessment disputes under the Income-tax Act were treated as requiring fresh examination where the first appellate relief had been granted only on jurisdictional grounds and the additions on merits had not been adjudicated. The Tribunal indicated that a direction to withdraw the reassessment notice was not sustainable in that posture, particularly where factual questions such as alleged accommodation entries and transaction genuineness remained unresolved. Both assessment years were therefore sent back for de novo reassessment with an opportunity of hearing, and the connected cross-objections were restored for decision along with the reassessment proceedings.</description>
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      <description>Reassessment disputes under the Income-tax Act were treated as requiring fresh examination where the first appellate relief had been granted only on jurisdictional grounds and the additions on merits had not been adjudicated. The Tribunal indicated that a direction to withdraw the reassessment notice was not sustainable in that posture, particularly where factual questions such as alleged accommodation entries and transaction genuineness remained unresolved. Both assessment years were therefore sent back for de novo reassessment with an opportunity of hearing, and the connected cross-objections were restored for decision along with the reassessment proceedings.</description>
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