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    <title>2026 (7) TMI 433 - GUJARAT HIGH COURT</title>
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    <description>Reopening under Section 148 failed because the recorded reason was limited to alleged inflation of closing work in progress, and that basis did not support the asserted escapement of income. The HC also held that the objection-disposal order was invalid because it introduced a new ground of alleged suppression of sales or other income, which was outside the original recorded reasons. Reassessment proceedings must stand or fall on the reasons recorded when notice is issued, and those reasons cannot be substituted by a fresh ground at the objections stage. The notice and the order rejecting objections were quashed in favour of the assessee.</description>
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    <pubDate>Mon, 22 Jun 2026 00:00:00 +0530</pubDate>
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      <title>2026 (7) TMI 433 - GUJARAT HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=794547</link>
      <description>Reopening under Section 148 failed because the recorded reason was limited to alleged inflation of closing work in progress, and that basis did not support the asserted escapement of income. The HC also held that the objection-disposal order was invalid because it introduced a new ground of alleged suppression of sales or other income, which was outside the original recorded reasons. Reassessment proceedings must stand or fall on the reasons recorded when notice is issued, and those reasons cannot be substituted by a fresh ground at the objections stage. The notice and the order rejecting objections were quashed in favour of the assessee.</description>
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