Reassessment under the amended scheme may be initiated where...

Reassessment under the amended scheme may be initiated where portal information links transactions to an assessee's PAN, provided the material is relevant and the assessing authority applies its mind to objections. Detailed reasons to believe are not required at the initiation stage. A GST communication does not bar an independent income-tax enquiry where identity theft has not been conclusively established. Reassessment may therefore continue, while the identity-theft defence remains open for examination. Although the assessee must substantiate that plea with evidence, the Revenue must first establish through positive primary evidence that the disputed transactions were undertaken by the assessee rather than another person.