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    <title>2026 (10) TMI 265 - ITAT DELHI</title>
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    <description>Reassessment jurisdiction under Sections 147(1) and 148 requires the Assessing Officer to form a bona fide belief, based on relevant tangible material, that income chargeable to tax has escaped assessment. Recorded reasons stating only that claims required verification or that supporting particulars were unavailable establish, at most, a reason to suspect. Where available financial statements were not scrutinised and no belief of income escapement was recorded, the statutory jurisdictional conditions were not met; the Section 148 notice and consequential reassessment were without jurisdiction and quashed.</description>
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