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    <title>2026 (10) TMI 525 - ITAT DELHI</title>
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    <description>Reassessment of a completed scrutiny assessment for alleged bogus long-term capital gains requires reasons to believe based on fresh tangible material, not a review of an issue already examined. Where share transactions, including purchase, demat and sale evidence, were scrutinised and the relevant gain was accepted, a later investigation report that does not identify the assessee or address existing material cannot establish income escapement. After the prescribed period, reopening additionally requires an uncontroverted failure to make full and true disclosure. On these facts, reassessment was invalid as a mere change of opinion.</description>
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    <pubDate>Fri, 25 Sep 2026 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=800582</link>
      <description>Reassessment of a completed scrutiny assessment for alleged bogus long-term capital gains requires reasons to believe based on fresh tangible material, not a review of an issue already examined. Where share transactions, including purchase, demat and sale evidence, were scrutinised and the relevant gain was accepted, a later investigation report that does not identify the assessee or address existing material cannot establish income escapement. After the prescribed period, reopening additionally requires an uncontroverted failure to make full and true disclosure. On these facts, reassessment was invalid as a mere change of opinion.</description>
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