https://www.taxtmi.com/caselaws?id=255620 Reopening of assessment was held invalid where the recorded reasons alleged that the assessee's industrial undertaking was not manufacturing activity and had been formed by splitting up an existing business, but the file contained no material to support that inference. In the absence of fresh or supporting material, the reassessment could not be founded on a mere allegation. The fact that the deduction claim had not previously been disallowed on that ground further showed that the stated basis for reopening was unsustainable. The decision confirms that reassessment must rest on relevant material and cannot proceed on unsupported assumptions. en-us Wed, 24 Dec 2014 00:00:00 +0530 Wed, 21 Jan 2015 14:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=255620 Reopening of assessment was held invalid where the recorded reasons alleged that the assessee's industrial undertaking was not manufacturing activity and had been formed by splitting up an existing business, but the file contained no material to support that inference. In the absence of fresh or supporting material, the reassessment could not be founded on a mere allegation. The fact that the deduction claim had not previously been disallowed on that ground further showed that the stated basis for reopening was unsustainable. The decision confirms that reassessment must rest on relevant material and cannot proceed on unsupported assumptions. Case-Laws Income Tax Wed, 24 Dec 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=255620