https://www.taxtmi.com/caselaws?id=252903 Reassessment under section 147 requires recorded reasons to show tangible material and a bona fide belief that income has escaped assessment, supported by a live nexus between the material and the proposed reopening. Where the assessee had disclosed its tax residency status and furnished a Tax Residency Certificate, reopening based only on a speculative possibility that it might not be a taxable unit in Denmark and might not qualify for treaty relief was invalid. A reopening founded on conjecture, hypothesis, or an unverified attempt to examine possible taxability lacks the rational connection required by law, and the reassessment notice and proceedings under sections 147 and 148 were quashed. en-us Fri, 31 Oct 2014 00:00:00 +0530 Mon, 23 Feb 2015 14:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=252903 Reassessment under section 147 requires recorded reasons to show tangible material and a bona fide belief that income has escaped assessment, supported by a live nexus between the material and the proposed reopening. Where the assessee had disclosed its tax residency status and furnished a Tax Residency Certificate, reopening based only on a speculative possibility that it might not be a taxable unit in Denmark and might not qualify for treaty relief was invalid. A reopening founded on conjecture, hypothesis, or an unverified attempt to examine possible taxability lacks the rational connection required by law, and the reassessment notice and proceedings under sections 147 and 148 were quashed. Case-Laws Income Tax Fri, 31 Oct 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=252903