https://www.taxtmi.com/caselaws?id=795354 Reassessment under the substituted regime was void because the pre-notice process did not extend the limitation deadline, and the notice was issued after that deadline. The extended limitation period was also unavailable because the alleged escaped income, rather than gross sale consideration, fell below the statutory threshold. Additions for alleged bogus penny-stock sale proceeds and estimated commission were unsustainable: abnormal price movement, general investigation material and human-probability inferences did not establish that the taxpayer used an accommodation entry. Cogent evidence linking the taxpayer to the alleged arrangement was required to displace documentary evidence. en-us Fri, 17 Jul 2026 00:00:00 +0530 Tue, 21 Jul 2026 08:32:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795354 Reassessment under the substituted regime was void because the pre-notice process did not extend the limitation deadline, and the notice was issued after that deadline. The extended limitation period was also unavailable because the alleged escaped income, rather than gross sale consideration, fell below the statutory threshold. Additions for alleged bogus penny-stock sale proceeds and estimated commission were unsustainable: abnormal price movement, general investigation material and human-probability inferences did not establish that the taxpayer used an accommodation entry. Cogent evidence linking the taxpayer to the alleged arrangement was required to displace documentary evidence. Case-Laws Income Tax Fri, 17 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795354