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Unverified Insight Portal information cannot justify...
Unverified Insight Portal Information Cannot Justify Reassessment Without a Verified Taxpayer-Specific Income-Escape Nexus or Demonstrated Application of Mind
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Unverified Insight Portal information cannot justify reassessment where it does not identify any transaction linking the taxpayer to alleged escaped income. Reassessment must rest on material demonstrating a taxpayer-specific nexus and application of mind; it cannot be used for a roving and fishing inquiry. Where the underlying material is not supplied, the alleged-beneficiary chart identifies no attributable transaction, and the Assessing Officer does not verify the information's genuineness, the reassessment notice and order under section 148A(3) lack a valid foundation. The reassessment proceedings were quashed and the writ petition was allowed.
Unverified Insight Portal information cannot justify reassessment where it does not identify any transaction linking the taxpayer to alleged escaped income. Reassessment must rest on material demonstrating a taxpayer-specific nexus and application of mind; it cannot be used for a roving and fishing inquiry. Where the underlying material is not supplied, the alleged-beneficiary chart identifies no attributable transaction, and the Assessing Officer does not verify the information's genuineness, the reassessment notice and order under section 148A(3) lack a valid foundation. The reassessment proceedings were quashed and the writ petition was allowed.
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