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HC determined the reopening assessment under s.147 was invalid as it constituted mere change of opinion. The AO's reliance on cash deposit information from Insight Portal did not qualify as fresh material since this data was previously examined during regular assessment. The court found no legitimate basis for the AO's "reason to believe" income had escaped assessment, as the information lacked new elements establishing a live nexus. Consequently, the s.148 notice for AY 2017-18 was quashed for lack of jurisdiction. The ruling emphasizes that reassessment cannot be initiated based on reexamination of existing material already considered during original assessment proceedings.
HC determined the reopening assessment under s.147 was invalid as it constituted mere change of opinion. The AO's reliance on cash deposit information from Insight Portal did not qualify as fresh material since this data was previously examined during regular assessment. The court found no legitimate basis for the AO's "reason to believe" income had escaped assessment, as the information lacked new elements establishing a live nexus. Consequently, the s.148 notice for AY 2017-18 was quashed for lack of jurisdiction. The ruling emphasizes that reassessment cannot be initiated based on reexamination of existing material already considered during original assessment proceedings.
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