Reassessment requires the prescribed preliminary inquiry and...

Reassessment requires the prescribed preliminary inquiry and independent application of mind; reliance solely on external reports fails the statutory preconditions and renders initiation without jurisdiction. An approved corporate insolvency resolution plan precludes reassessment or revision of pre-effective-date claims that were not included in the plan, as such claims are frozen or extinguished under the overriding insolvency framework. Complete disclosure of relied-upon third-party statements and materials is necessary to afford a fair rebuttal opportunity; non-disclosure breaches natural justice. Reassessment must also commence within the Income-tax Act's prescribed limitation period; proceedings initiated after that period are invalid.