2026 (2) TMI 817 - SCH - Income Tax

Reopening of assessment: failure to consider objections severs nexus between material and reason to believe, invalidating reassessment basis.

Reopening of assessment under tax law is examined with focus on the 'reason to believe' standard and the assessing officer's duty to address taxpayer ... Reopening of assessment u/s 147 - reasons to believe - Non disposal of objections Ld' A.S.G. has pointed out that arising from the common impugned order another Special Leave Petition (C) filed was dismissed 2026 (1) TMI 375 - SC ORDER] As decided by HC [2025 (4) TMI 544 - GUJARAT HIGH COURT] AO has failed to consider the objections of the petitioner in the true perspective and in absence of any material pertaining to the details relating to the petitioner, so as to prove that income has escaped assessment, we are of the opinion that there is no link between the material and the reasons recorded, resulting into dis-satisfaction on the part of the AO HELD THAT:- Special Leave Petition is dismissed. Outcome: Special Leave Petition dismissed [No detailed order].