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Reopening of assessment must be founded on recorded satisfaction...
Reopening Assessments invalid where satisfaction and jurisdictional approval are absent for third party seized material, leading to quashing of assessment.
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Reopening of assessment must be founded on recorded satisfaction that seized material relates to the assessee when that material was seized from a third person; the assessing officer must demonstrate nexus between the seized material and escapement of income and obtain requisite jurisdictional approval before issuing notice. Where the AO treated third party search material as if searched in the assessee's premises, relied on employee laptop and pen drive data without satisfying the statutory preconditions or proving nexus, the notice under reopening provision and resulting assessment are void and liable to be quashed.
Reopening of assessment must be founded on recorded satisfaction that seized material relates to the assessee when that material was seized from a third person; the assessing officer must demonstrate nexus between the seized material and escapement of income and obtain requisite jurisdictional approval before issuing notice. Where the AO treated third party search material as if searched in the assessee's premises, relied on employee laptop and pen drive data without satisfying the statutory preconditions or proving nexus, the notice under reopening provision and resulting assessment are void and liable to be quashed.
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