Reassessment jurisdiction failed because reopening reasons relied on unverified and incorrect cash-deposit information before issuing notice.

Reassessment jurisdiction requires recorded reasons founded on verified and factually accurate information, with independent application of mind before issuing notice. The notes state that the reopening reasons attributed higher cash deposits than those shown in the subsequently obtained bank statement, and that bank information was sought only after the notice was issued. Reopening based on incorrect foundational facts without prior enquiry did not meet the conditions for reassessment jurisdiction. The reopening under Section 148 and consequential reassessment were therefore void.

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Issues: Whether reassessment initiated on the basis of an incorrect cash-deposit figure, without prior verification or application of mind, was valid.

Analysis: The recorded reasons for reopening stated cash deposits of Rs. 43,99,000, whereas the bank statement subsequently obtained showed deposits of Rs. 23,24,000. The information from the bank was called for only after issuance of the reopening notice. Reopening founded on factually incorrect reasons, without independent enquiry or proper application of mind to the foundational information, did not satisfy the prerequisites for assumption of reassessment jurisdiction.

Conclusion: The reopening under Section 148 of the Income-tax Act, 1961 was quashed, and the consequential reassessment was void, in favour of the assessee.

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