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Reassessment jurisdiction cannot rest on unverified, factually...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries.
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Reassessment jurisdiction cannot rest on unverified, factually incorrect information or disregard the taxpayer's specific explanation. Aggregating distinct information-portal entries as escaped income, when only one entry was relevant, showed non-application of mind; the eventual addition also did not match the aggregated amount or one entry. Reopening on that premise was invalid because the Assessing Officer failed to verify the information before assuming jurisdiction and did not address the objection. The reassessment order was quashed and the appeal allowed.
Reassessment jurisdiction cannot rest on unverified, factually incorrect information or disregard the taxpayer's specific explanation. Aggregating distinct information-portal entries as escaped income, when only one entry was relevant, showed non-application of mind; the eventual addition also did not match the aggregated amount or one entry. Reopening on that premise was invalid because the Assessing Officer failed to verify the information before assuming jurisdiction and did not address the objection. The reassessment order was quashed and the appeal allowed.
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