Reassessment based on unverified portal information failed for lack of independent inquiry and live nexus with escapement of income.

Reassessment under sections 147 and 148 was invalid because the Assessing Officer relied only on portal-based information without independent verification, inquiry, or a live nexus between the material and the belief of escapement of income; the reopening was quashed. On merits, the unsecured loan addition was unsustainable because the assessee produced confirmations, ledger accounts, bank statements, and lender return details, while the transaction was routed through banking channels and repaid in the same year; the addition was deleted.

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Issues: (i) Whether reassessment under sections 147 and 148 of the Income-tax Act, 1961 was valid when the Assessing Officer relied only on portal-based information without independent verification; (ii) Whether the addition made on account of the unsecured loan was sustainable.

Issue (i): Whether reassessment under sections 147 and 148 of the Income-tax Act, 1961 was valid when the Assessing Officer relied only on portal-based information without independent verification.

Analysis: The reassessment was initiated on information downloaded from the department portal, but the Assessing Officer did not verify the material, did not examine whether any corresponding addition or scrutiny existed in the lender's case, and did not make any independent enquiry before forming the belief of escapement of income. The record showed that the loan was received through banking channels and repaid through banking channels during the year. In the absence of a live nexus between the material and the belief recorded, the statutory requirement of reason to believe was not satisfied.

Conclusion: The reopening was invalid and was rightly quashed in favour of the assessee.

Issue (ii): Whether the addition made on account of the unsecured loan was sustainable.

Analysis: The assessee furnished confirmations, ledger account, bank statement, and return details of the lender. The Assessing Officer accepted the portal information as conclusive without examining the assessee's evidence or issuing any effective verification to the lender. As the transaction was routed through banking channels and repaid in the same year, the addition could not stand on the basis of an unverified allegation of accommodation entry.

Conclusion: The addition was unsustainable and was deleted in favour of the assessee.

Final Conclusion: The appeal succeeded on both jurisdiction and merits, with the reassessment annulled and the impugned addition deleted.

Ratio Decidendi: Reassessment under sections 147 and 148 requires independent application of mind and a live nexus between tangible material and the belief of escapement of income; unverified portal information alone cannot sustain reopening or addition.

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