https://www.taxtmi.com/caselaws?id=237378 Reassessment under the Income Tax Act requires recorded reasons showing a rational nexus between material available to the Assessing Officer and a reasonable belief that income escaped assessment. Mere suspicion, conjecture, or reconsideration of matters fully disclosed in the original assessment cannot support reopening. Where no new material has come to the Assessing Officer's knowledge and the stated basis concerns prior-period expenses already available for consideration, the statutory threshold for reopening is not met. The discussion emphasises that the belief must arise from direct or circumstantial evidence and cannot rest on a change of opinion. en-us Fri, 23 Aug 2013 00:00:00 +0530 Mon, 22 Sep 2025 14:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=237378 Reassessment under the Income Tax Act requires recorded reasons showing a rational nexus between material available to the Assessing Officer and a reasonable belief that income escaped assessment. Mere suspicion, conjecture, or reconsideration of matters fully disclosed in the original assessment cannot support reopening. Where no new material has come to the Assessing Officer's knowledge and the stated basis concerns prior-period expenses already available for consideration, the statutory threshold for reopening is not met. The discussion emphasises that the belief must arise from direct or circumstantial evidence and cannot rest on a change of opinion. Case-Laws Income Tax Fri, 23 Aug 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=237378