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    <title>2024 (8) TMI 1774 - ITAT AMRITSAR</title>
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    <description>Reassessment jurisdiction requires recorded reasons that accurately arise from the material available to the Assessing Officer. Where registered deeds showed that sales and purchases had been incorrectly reversed and a sale was treated as unexplained investment, the reasons disclosed non-application of mind and could not support a belief that income had escaped assessment. Jurisdiction must be assessed solely from the recorded reasons; later explanations cannot supplement or correct them. Such foundational factual errors are not technical defects protected by Section 292B. Consequently, the Section 148 notice was void from inception and the reassessment was invalid.</description>
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      <description>Reassessment jurisdiction requires recorded reasons that accurately arise from the material available to the Assessing Officer. Where registered deeds showed that sales and purchases had been incorrectly reversed and a sale was treated as unexplained investment, the reasons disclosed non-application of mind and could not support a belief that income had escaped assessment. Jurisdiction must be assessed solely from the recorded reasons; later explanations cannot supplement or correct them. Such foundational factual errors are not technical defects protected by Section 292B. Consequently, the Section 148 notice was void from inception and the reassessment was invalid.</description>
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