Preliminary reassessment proceedings generally require statutory remedies unless jurisdiction is wholly absent or mandatory conditions are patently br...
Agricultural land classification requires cumulative factual indicators, while industrial-purpose land and absent agricultural use defeat reinvestment...
Reassessment under section 148 was quashed because the recorded reasons were vague, factually inconsistent and unsupported by an independent application of mind. The Tribunal found that the Assessing Officer relied on portal information and investigation material alleging fictitious profit, but the reassessment order treated the same figure differently and failed to maintain the very basis on which jurisdiction was assumed. No live nexus was shown between the material and escapement of income, and the assessee's purchase, sale, bank and D-Mat records were not dislodged by adverse material. The reopening was held to rest on borrowed satisfaction, so the reassessment was unsustainable and the merits were not examined.
Reassessment under section 148 was quashed because the recorded reasons were vague, factually inconsistent and unsupported by an independent application of mind. The Tribunal found that the Assessing Officer relied on portal information and investigation material alleging fictitious profit, but the reassessment order treated the same figure differently and failed to maintain the very basis on which jurisdiction was assumed. No live nexus was shown between the material and escapement of income, and the assessee's purchase, sale, bank and D-Mat records were not dislodged by adverse material. The reopening was held to rest on borrowed satisfaction, so the reassessment was unsustainable and the merits were not examined.
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