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    <title>2026 (10) TMI 611 - ITAT CHANDIGARH</title>
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    <description>Reassessment initiated beyond four years requires a reasoned belief that income escaped assessment because the taxpayer failed to make a full and true disclosure of material facts. Third-party search information adopted without independent enquiry or a direct nexus to the taxpayer&#039;s records does not meet that jurisdictional threshold; the reassessment was therefore quashed. Section 69C requires proof that unexplained expenditure was actually incurred. Where export receipts were supported by contemporaneous business, customs and banking records, uncorroborated third-party material without effective cross-examination could not establish cash payments or unexplained expenditure. The addition was deleted, avoiding double taxation of recorded export receipts.</description>
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      <link>https://www.taxtmi.com/caselaws?id=800668</link>
      <description>Reassessment initiated beyond four years requires a reasoned belief that income escaped assessment because the taxpayer failed to make a full and true disclosure of material facts. Third-party search information adopted without independent enquiry or a direct nexus to the taxpayer&#039;s records does not meet that jurisdictional threshold; the reassessment was therefore quashed. Section 69C requires proof that unexplained expenditure was actually incurred. Where export receipts were supported by contemporaneous business, customs and banking records, uncorroborated third-party material without effective cross-examination could not establish cash payments or unexplained expenditure. The addition was deleted, avoiding double taxation of recorded export receipts.</description>
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