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    <title>Borrowed satisfaction invalidates reassessment when alleged escaped income differs from the share loss ultimately disallowed.</title>
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    <description>Reassessment based on third-party information was invalid where the recorded reasons alleged escaped income but the assessment disallowed a materially different penny-stock share-sale loss, demonstrating no independent application of mind and borrowed satisfaction. A claimed short-term capital loss on sale of shares remained allowable where contract notes, banking and broker records, demat records, and investment-account entries evidenced exchange-traded transactions through a registered broker, and no defect in that evidence was identified; general penny-stock allegations were insufficient. The Revenue&#039;s challenge to deletion of the loss disallowance was dismissed, while proceedings for another assessment year were remitted for fresh adjudication.</description>
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    <pubDate>Sat, 31 Oct 2026 08:32:14 +0530</pubDate>
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      <title>Borrowed satisfaction invalidates reassessment when alleged escaped income differs from the share loss ultimately disallowed.</title>
      <link>https://www.taxtmi.com/highlights?id=105646</link>
      <description>Reassessment based on third-party information was invalid where the recorded reasons alleged escaped income but the assessment disallowed a materially different penny-stock share-sale loss, demonstrating no independent application of mind and borrowed satisfaction. A claimed short-term capital loss on sale of shares remained allowable where contract notes, banking and broker records, demat records, and investment-account entries evidenced exchange-traded transactions through a registered broker, and no defect in that evidence was identified; general penny-stock allegations were insufficient. The Revenue&#039;s challenge to deletion of the loss disallowance was dismissed, while proceedings for another assessment year were remitted for fresh adjudication.</description>
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      <pubDate>Sat, 31 Oct 2026 08:32:14 +0530</pubDate>
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