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    <title>2026 (8) TMI 390 - GUJARAT HIGH COURT</title>
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    <description>Reassessment based solely on a suspicious transaction report was invalid where audited financial statements, capital accounts and tax-audit material showed that the questioned receipts were capital infusion or withdrawal by a partner under the partnership arrangement. Withdrawal of a partner&#039;s capital balance did not itself demonstrate income escaping assessment, and the reassessment order failed to address the taxpayer&#039;s explanation and supporting evidence. In the absence of third-party statements, incriminating material, or evidence that the bank transactions were bogus or accommodation entries, mere suspicion could not justify reopening. The reassessment notices and orders were quashed.</description>
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    <pubDate>Mon, 27 Jul 2026 00:00:00 +0530</pubDate>
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      <description>Reassessment based solely on a suspicious transaction report was invalid where audited financial statements, capital accounts and tax-audit material showed that the questioned receipts were capital infusion or withdrawal by a partner under the partnership arrangement. Withdrawal of a partner&#039;s capital balance did not itself demonstrate income escaping assessment, and the reassessment order failed to address the taxpayer&#039;s explanation and supporting evidence. In the absence of third-party statements, incriminating material, or evidence that the bank transactions were bogus or accommodation entries, mere suspicion could not justify reopening. The reassessment notices and orders were quashed.</description>
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