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HC invalidated reassessment proceedings initiated under Section 148 of Income Tax Act for AY 2014-15. The discovery of cash and gold during search operations on 03.09.2013 from assessee and related parties did not constitute valid "reason to believe" for reopening assessment. AO was already aware of search proceedings and seizures when passing original assessment order under Section 143(3). No failure to disclose material facts was established by revenue. Mere recovery of amounts cannot justify reopening without establishing direct nexus between undisclosed income and seized assets. Court emphasized need for tangible material and live link between information and escaped income for valid reopening. Original assessment could have been revised under Section 263 if found erroneous and prejudicial to revenue interests.
HC invalidated reassessment proceedings initiated under Section 148 of Income Tax Act for AY 2014-15. The discovery of cash and gold during search operations on 03.09.2013 from assessee and related parties did not constitute valid "reason to believe" for reopening assessment. AO was already aware of search proceedings and seizures when passing original assessment order under Section 143(3). No failure to disclose material facts was established by revenue. Mere recovery of amounts cannot justify reopening without establishing direct nexus between undisclosed income and seized assets. Court emphasized need for tangible material and live link between information and escaped income for valid reopening. Original assessment could have been revised under Section 263 if found erroneous and prejudicial to revenue interests.
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