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    <title>Reassessment on Borrowed Satisfaction Fails When Recorded Share Transactions Were Already Examined and Accepted in Scrutiny</title>
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    <description>Reassessment founded on misstated facts, mechanically adopted investigation inputs, and transactions already examined in scrutiny constitutes an impermissible change of opinion and is invalid. Section 69A does not apply to recorded equity-share purchases where contract notes, broker records, and bank evidence establish the source of investment. It also cannot treat accounted sale proceeds of recorded shares as unexplained investment; taxing those proceeds again after the related income has been offered results in double taxation. Failure to verify supporting material or permit cross-examination of a retracted third-party statement further undermines the addition.</description>
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    <pubDate>Wed, 21 Oct 2026 08:37:56 +0530</pubDate>
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      <title>Reassessment on Borrowed Satisfaction Fails When Recorded Share Transactions Were Already Examined and Accepted in Scrutiny</title>
      <link>https://www.taxtmi.com/highlights?id=105223</link>
      <description>Reassessment founded on misstated facts, mechanically adopted investigation inputs, and transactions already examined in scrutiny constitutes an impermissible change of opinion and is invalid. Section 69A does not apply to recorded equity-share purchases where contract notes, broker records, and bank evidence establish the source of investment. It also cannot treat accounted sale proceeds of recorded shares as unexplained investment; taxing those proceeds again after the related income has been offered results in double taxation. Failure to verify supporting material or permit cross-examination of a retracted third-party statement further undermines the addition.</description>
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      <pubDate>Wed, 21 Oct 2026 08:37:56 +0530</pubDate>
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