The HC held that the respondent Assessing Officer lacked...

The HC held that the respondent Assessing Officer lacked jurisdiction to reopen assessment, finding the impugned show-cause notices constituted a mere fishing inquiry and were issued without material having a live nexus to the sale-deed. Information from the public domain and the DVO's valuation report were held insufficient to prima facie establish payment of on-money; the valuation report being only an opinion requiring corroborative evidence. Because the records showed the sale-deed predated the search and transactions relied upon, the notices were held to be without jurisdiction and were quashed and set aside, with consequential relief as appropriate to the petitioners.

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