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    <title>2026 (8) TMI 679 - ITAT RANCHI</title>
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    <description>Reassessment notices for assessment years 2014-15 to 2016-17 under Section 148 were invalid because they relied on investigation-wing information received before 4 March 2021, rather than cases flagged through the prescribed post-4 March 2021 process. The additional legal ground was admissible as it arose from facts already on record and went to the root of the assessments. CBDT instructions, clarified on 12 March 2021, restricted selection of investigation-report cases for reassessment to the specified process and did not permit jurisdictional Assessing Officers to select other cases. The notices and consequential reassessments were quashed.</description>
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      <title>2026 (8) TMI 679 - ITAT RANCHI</title>
      <link>https://www.taxtmi.com/caselaws?id=796806</link>
      <description>Reassessment notices for assessment years 2014-15 to 2016-17 under Section 148 were invalid because they relied on investigation-wing information received before 4 March 2021, rather than cases flagged through the prescribed post-4 March 2021 process. The additional legal ground was admissible as it arose from facts already on record and went to the root of the assessments. CBDT instructions, clarified on 12 March 2021, restricted selection of investigation-report cases for reassessment to the specified process and did not permit jurisdictional Assessing Officers to select other cases. The notices and consequential reassessments were quashed.</description>
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      <pubDate>Fri, 31 Jul 2026 00:00:00 +0530</pubDate>
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