Reassessment requires recorded material to have a rational connection and live nexus with the belief that income escaped assessment; suspicion based on statements or survey material unrelated to the taxpayer or investment transaction is insufficient. Allegations concerning an investor's representative, without transaction-specific material, could not support reopening for purportedly non-genuine share capital and share premium. For employees' provident fund and insurance contributions, the law prevailing when notice was issued allowed deduction where payment was made by the return-filing due date. A later contrary Supreme Court ruling could not retrospectively validate the recorded reason. The reassessment notice was quashed because neither ground established a sustainable reason to believe.
Reassessment requires recorded material to have a rational connection and live nexus with the belief that income escaped assessment; suspicion based on statements or survey material unrelated to the taxpayer or investment transaction is insufficient. Allegations concerning an investor's representative, without transaction-specific material, could not support reopening for purportedly non-genuine share capital and share premium. For employees' provident fund and insurance contributions, the law prevailing when notice was issued allowed deduction where payment was made by the return-filing due date. A later contrary Supreme Court ruling could not retrospectively validate the recorded reason. The reassessment notice was quashed because neither ground established a sustainable reason to believe.
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