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    <title>2026 (10) TMI 761 - GUJARAT HIGH COURT</title>
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    <description>Reassessment requires material indicating that income chargeable to tax escaped assessment in the specific assessment year proposed for reopening. Unsecured loans had been obtained and disclosed in the preceding year, while the relevant year&#039;s ledger reflected only interest expenditure. The loan amounts cited in the reopening material also did not match the recorded interest amount. Because the alleged loan transactions did not pertain to the year reopened, the reassessment lacked a sustainable factual basis and was unsustainable.</description>
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