https://www.taxtmi.com/caselaws?id=352601 Reassessment under section 147 must rest on the Assessing Officer's own belief based on tangible material, not borrowed satisfaction from another officer or uncorroborated third-party information. Where the reasons do not show a direct nexus between the material and the alleged escapement, reopening is invalid. An addition for unexplained investment likewise cannot stand without evidence of the assessee's actual cash payment, the quantum involved, and the year or mode of payment. In the absence of direct or corroborative evidence linking the assessee to alleged on-money, the reassessment and related addition were held unsustainable and the Revenue's appeals failed. en-us Wed, 15 Nov 2017 00:00:00 +0530 Mon, 18 Dec 2017 11:34:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=352601 Reassessment under section 147 must rest on the Assessing Officer's own belief based on tangible material, not borrowed satisfaction from another officer or uncorroborated third-party information. Where the reasons do not show a direct nexus between the material and the alleged escapement, reopening is invalid. An addition for unexplained investment likewise cannot stand without evidence of the assessee's actual cash payment, the quantum involved, and the year or mode of payment. In the absence of direct or corroborative evidence linking the assessee to alleged on-money, the reassessment and related addition were held unsustainable and the Revenue's appeals failed. Case-Laws Income Tax Wed, 15 Nov 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=352601