Reassessment founded on seized material requires a live and...

Reassessment founded on seized material requires a live and direct nexus between the material and the assessee. An inquiry-register entry held by a real-estate broker, which predated the land purchase, reflected land offered for sale and an asking rate rather than a completed transaction. As the entry neither identified nor linked the assessee or co-purchasers, and the named person was not examined, a survey-number match alone could not establish unrecorded consideration. The notice reopening assessment was therefore quashed as based on conjecture and surmise rather than material linked to the assessee.