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TaxTMI AI Drafter workflow from input facts to final legal draft Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.

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Assessment Reopening Invalid: Profits from Accommodation Entries Already Disclosed and Assessed, No Justifiable Belief of Escaped Income.

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....Reopening of assessment - receipt of accommodation entries - Such profit has been duly accounted, disclosed and assessed. Therefore the AO could not form a belief at the time of issue of notice that income to that extent has escaped assessment. - AT....