Tangible material requirement for reassessment: reopening failed where disclosed receipts and identical reasons showed no live link to escapement.

Reassessment under section 147 requires fresh or tangible material giving a live link to a belief that income has escaped assessment. Where the assessee had already disclosed the relevant receipts in the return computation and audit report, and the recorded reasons were substantially identical to those considered in earlier years and connected cases, there was no valid basis for reopening. The fact that the original return was processed under section 143(1) did not remove the need for such material. The reopening was therefore held invalid and the reassessment proceedings were quashed.

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Issues: Whether reassessment under section 147 was valid in the absence of tangible material showing escapement of income.

Analysis: The assessee had disclosed the relevant receipts in the return computation and in the audit report in Form No. 3CEB. The reasons recorded for reopening were substantially identical to those considered in earlier years and in connected cases. On these facts, there was no fresh or tangible material to support a belief that income had escaped assessment. The requirement under section 147 is that the reason to believe must have a live link with material available to the Assessing Officer; the fact that the original processing was under section 143(1) did not dispense with that requirement.

Conclusion: The reassessment proceedings were held to be invalid and bad in law, and the reopening was quashed.

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