Reassessment reopening based on closed tax evasion petition and general information was quashed for want of actionable material.

Reassessment could not be sustained where the recorded reasons for reopening lost their foundation after a letter before the HC showed that the tax evasion petition had already been closed. The material relied on was only general information, found to be devoid of merit and non-actionable, so it could not justify initiation of reassessment. On that basis, the objections to reopening were also unsustainable. The impugned reopening-related order and the letter disposing of objections were quashed.

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Issues: Whether the reassessment proceedings and the order disposing of objections could stand when the letter relied upon showed that the tax evasion petition had been closed and the information was general in nature and without merit.

Analysis: The reasons recorded for reopening were found to have lost their foundation once the letter tendered before the Court disclosed that the tax evasion petition had already been closed and the material was only general information, devoid of merit and non-actionable. On that basis, the objections to initiation of reassessment could not be sustained.

Conclusion: The challenge succeeded and the impugned reopening-related order and objection-disposal letter were quashed, with the petition allowed.

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