Reason to believe for reassessment requires live material; portal-based suspicion alone cannot justify reopening.

Reassessment notice was not struck down on territorial jurisdiction grounds because the assessee remained within the same jurisdiction, had earlier filed its return before the issuing Assessing Officer, and did not establish timely intimation of any jurisdictional change after the name and PAN alteration. However, the reopening failed on merits because the recorded reasons based on portal information did not disclose concrete transaction-level material linking the assessee to alleged escapement of income. A mere suspicion or generic reference to accommodation entries and cash deposits was treated as a fishing inquiry, so the notice was quashed for want of a bona fide reason to believe.

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Issues: (i) Whether the notice issued for reassessment was without jurisdiction on the ground that the Assessing Officer lacked territorial jurisdiction after the change of the assessee's name and PAN. (ii) Whether the reassessment notice was vitiated for want of a bona fide "reason to believe" that income had escaped assessment.

Issue (i): Whether the notice issued for reassessment was without jurisdiction on the ground that the Assessing Officer lacked territorial jurisdiction after the change of the assessee's name and PAN.

Analysis: The statutory scheme of jurisdiction under sections 120 and 124 recognises allocation of powers among income-tax authorities and also contemplates concurrent or overlapping jurisdiction within the same territorial area. The Court found that the assessee remained within the same territorial jurisdiction and had earlier filed its return before the very Assessing Officer who issued the notice. It further noted that the assessee had not established timely intimation of change of jurisdiction on account of name change and new PAN in the manner asserted. On these facts, the notice could not be treated as lacking jurisdiction merely because the assessee's name had changed.

Conclusion: The jurisdictional challenge was rejected and the notice was not held to be without jurisdiction.

Issue (ii): Whether the reassessment notice was vitiated for want of a bona fide "reason to believe" that income had escaped assessment.

Analysis: For action under sections 147 and 148, the Assessing Officer must have relevant material bearing a live nexus to the alleged escapement of income. The reasons recorded were based on information from the insight portal, but they did not disclose any concrete material connecting the assessee's books and transactions with the alleged accommodation entries or cash deposits. The Court held that a mere reference to portal-based information, without details of the nature and date of transactions or supporting material showing escapement, amounted to an attempt at fishing and roving inquiry rather than a bona fide reassessment trigger.

Conclusion: The reassessment notice was invalid for absence of a valid reason to believe and was quashed.

Final Conclusion: The reassessment notice was set aside because the recorded reasons did not furnish a legally sustainable basis for reopening, even though the jurisdictional objection failed.

Ratio Decidendi: Reassessment cannot be sustained unless the recorded reasons disclose relevant material having a live nexus with the alleged escapement of income, and a mere portal-based suspicion without supporting transaction-level particulars does not satisfy the statutory requirement of reason to believe.

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