https://www.taxtmi.com/caselaws?id=799052 Reassessment notices alleging fictitious or accommodation transactions must disclose sufficient material particulars and the relied-upon incriminating material that prima facie links the assessee to the alleged income escapement. Transaction screenshots identifying values and entities, without the underlying dissemination reports, do not provide an effective opportunity to respond under the statutory pre-notice procedure. The Assessing Officer must meaningfully consider the assessee's documentary explanation and identify material supporting the alleged role in the transactions. Disclosure of relied-upon reports only during writ proceedings cannot cure the initial denial of a meaningful statutory opportunity. Reassessment proceedings initiated without such disclosure are invalid. en-us Mon, 07 Sep 2026 00:00:00 +0530 Wed, 16 Sep 2026 08:38:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799052 Reassessment notices alleging fictitious or accommodation transactions must disclose sufficient material particulars and the relied-upon incriminating material that prima facie links the assessee to the alleged income escapement. Transaction screenshots identifying values and entities, without the underlying dissemination reports, do not provide an effective opportunity to respond under the statutory pre-notice procedure. The Assessing Officer must meaningfully consider the assessee's documentary explanation and identify material supporting the alleged role in the transactions. Disclosure of relied-upon reports only during writ proceedings cannot cure the initial denial of a meaningful statutory opportunity. Reassessment proceedings initiated without such disclosure are invalid. Case-Laws Income Tax Mon, 07 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799052