Reassessment requires a live nexus and identifiable escaped income; vague allegations and unquantified reasons cannot justify reopening.

Reassessment under sections 147 and 148 cannot be sustained unless the recorded reasons disclose tangible material and a live nexus between that material and a reasoned belief that identifiable income has escaped assessment. Where the reasons rely on vague allegations of illegal mining and third-party reports but do not quantify the alleged escapement or show any actionable finding linking the material to the assessee, the reopening is treated as a fishing enquiry. On that basis, the reassessment notice was invalid and the proceedings were quashed.

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Issues: Whether reassessment under sections 147 and 148 of the Income-tax Act, 1961 was valid when the recorded reasons did not quantify the alleged escaped income or disclose a live link between the material relied upon and the belief that income had escaped assessment.

Analysis: The recorded reasons were found to be based on allegations of illegal mining and references to third-party reports, but they did not indicate even an approximate amount of income said to have escaped assessment. The material relied upon was treated as unsubstantiated for the assessee's case and as not having resulted in any live, actionable finding of illegal mining. In the absence of quantified escapement and a direct nexus between the information and the belief formed by the Assessing Officer, the reopening was held to amount to a fishing enquiry rather than a legally sustainable formation of belief.

Conclusion: The reassessment notice was invalid and was quashed.

Final Conclusion: The reassessment proceedings could not be sustained, and the assessee succeeded in both appeals.

Ratio Decidendi: Reassessment cannot be sustained unless the recorded reasons disclose tangible material with a live link to a reasoned belief that identifiable income has escaped assessment; vague allegations without quantification amount to a fishing enquiry.

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