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    <title>Recorded Escapement Requirement invalidates reassessment when unrelated share-sale income is added without assessing the recorded underpricing issue.</title>
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    <description>Reassessment requires the Assessing Officer to assess or reassess the income forming the recorded basis for reopening before making additions for any other escaped income identified during the proceedings. The provision allowing assessment of other escaped income permits consideration of a new issue but does not remove this prerequisite. Where no addition or adverse finding was made regarding the recorded underpricing of a share transfer, an addition for unexplained credit arising from a separate share-sale transaction could not be made independently. A fresh reopening notice was required. The reassessment was therefore without jurisdiction and non est, while the merits of the addition remained unadjudicated.</description>
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    <pubDate>Thu, 15 Oct 2026 05:44:05 +0530</pubDate>
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      <title>Recorded Escapement Requirement invalidates reassessment when unrelated share-sale income is added without assessing the recorded underpricing issue.</title>
      <link>https://www.taxtmi.com/highlights?id=105015</link>
      <description>Reassessment requires the Assessing Officer to assess or reassess the income forming the recorded basis for reopening before making additions for any other escaped income identified during the proceedings. The provision allowing assessment of other escaped income permits consideration of a new issue but does not remove this prerequisite. Where no addition or adverse finding was made regarding the recorded underpricing of a share transfer, an addition for unexplained credit arising from a separate share-sale transaction could not be made independently. A fresh reopening notice was required. The reassessment was therefore without jurisdiction and non est, while the merits of the addition remained unadjudicated.</description>
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      <pubDate>Thu, 15 Oct 2026 05:44:05 +0530</pubDate>
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