https://www.taxtmi.com/caselaws?id=236473 Reassessment under sections 147 and 148 is valid only if the recorded reasons show a live link between the material relied on and the belief that income escaped assessment. The reasons here merely recited the return, scrutiny assessment, project facts and offshore consultancy income, but did not explain how those facts justified reopening or why the original assessment was wrong. A bare assertion that the project created a permanent establishment and that income had escaped assessment was insufficient, as vague or inchoate reasons amount only to suspicion. The reassessment notice and the order disposing of objections were therefore set aside. en-us Thu, 22 Aug 2013 00:00:00 +0530 Sat, 26 Oct 2013 13:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=236473 Reassessment under sections 147 and 148 is valid only if the recorded reasons show a live link between the material relied on and the belief that income escaped assessment. The reasons here merely recited the return, scrutiny assessment, project facts and offshore consultancy income, but did not explain how those facts justified reopening or why the original assessment was wrong. A bare assertion that the project created a permanent establishment and that income had escaped assessment was insufficient, as vague or inchoate reasons amount only to suspicion. The reassessment notice and the order disposing of objections were therefore set aside. Case-Laws Income Tax Thu, 22 Aug 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=236473