Reassessment under section 148A requires information that...

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.