https://www.taxtmi.com/caselaws?id=330888 Reopening of assessment beyond four years was challenged on the ground that the AO lacked "reasons to believe" and acted only on investigation input. The HC held that the AO had tangible material in the form of specific information from the DGIT (Inv.) regarding search-based statements indicating the supplier was an accommodation-entry provider and that the assessee's diamond purchases were not genuine, enabling inflation of expenditure and suppression of profit. As this material was not available at the time of the original assessment and the AO independently applied his mind to it, the statutory preconditions for reassessment were satisfied. The reopening notice was upheld. en-us Tue, 02 Aug 2016 00:00:00 +0530 Mon, 05 Jan 2026 17:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=330888 Reopening of assessment beyond four years was challenged on the ground that the AO lacked "reasons to believe" and acted only on investigation input. The HC held that the AO had tangible material in the form of specific information from the DGIT (Inv.) regarding search-based statements indicating the supplier was an accommodation-entry provider and that the assessee's diamond purchases were not genuine, enabling inflation of expenditure and suppression of profit. As this material was not available at the time of the original assessment and the AO independently applied his mind to it, the statutory preconditions for reassessment were satisfied. The reopening notice was upheld. Case-Laws Income Tax Tue, 02 Aug 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=330888