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    <title>2026 (7) TMI 435 - GUJARAT HIGH COURT</title>
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    <description>Reassessment under the Income-tax Act based on an alleged cessation of liability was held unsustainable where the assessee had not claimed the disputed interest deduction and the reopening rested on conjecture. The court noted that the undertaking had been sold as a going concern in liquidation on a clean slate basis, with past liabilities treated as extinguished. Because the revenue did not verify the accounts and proceeded on an assumption that a deduction might have been claimed, the notice under Section 148 and the order under Section 148A(d) were quashed. The ruling reinforces that reassessment cannot proceed on mere surmise of income escapement.</description>
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      <link>https://www.taxtmi.com/caselaws?id=794549</link>
      <description>Reassessment under the Income-tax Act based on an alleged cessation of liability was held unsustainable where the assessee had not claimed the disputed interest deduction and the reopening rested on conjecture. The court noted that the undertaking had been sold as a going concern in liquidation on a clean slate basis, with past liabilities treated as extinguished. Because the revenue did not verify the accounts and proceeded on an assumption that a deduction might have been claimed, the notice under Section 148 and the order under Section 148A(d) were quashed. The ruling reinforces that reassessment cannot proceed on mere surmise of income escapement.</description>
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