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Reassessment under section 148A requires information that rationally and directly suggests income escapement; mere suspicion, a need for further scrutiny, or a verification objective is insufficient. The material and the taxpayer's response must be considered in a speaking order before a case is treated as fit for reassessment. Treating an entire trust's expenditure over several years as unexplained, despite accounts, bank records and vouchers, without identifying a false explanation or unaccounted amount, constitutes an impermissible roving or fishing inquiry. The reassessment order and consequential notice for the relevant assessment year were set aside.
Reassessment under section 148A requires information that rationally and directly suggests income escapement; mere suspicion, a need for further scrutiny, or a verification objective is insufficient. The material and the taxpayer's response must be considered in a speaking order before a case is treated as fit for reassessment. Treating an entire trust's expenditure over several years as unexplained, despite accounts, bank records and vouchers, without identifying a false explanation or unaccounted amount, constitutes an impermissible roving or fishing inquiry. The reassessment order and consequential notice for the relevant assessment year were set aside.
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