https://www.taxtmi.com/caselaws?id=12315 Reopening under ss. 147/148 beyond four years was challenged on the ground that the Assessing Officer lacked valid "reasons to believe" and that sanction under s. 151 was mechanical. The HC held that s. 148(2) requires reasons to be recorded on tangible material showing escapement of income; mere suspicion about a loan's genuineness, without any information on record linking the assessee to a bogus transaction, cannot found jurisdiction to reopen. Consequently, the notice was invalid. The HC further held that the approving authority under s. 151 must independently apply mind to the recorded reasons; routine approval breaches the statutory safeguard, vitiating the notice. The writ was allowed and the impugned s. 148 notice was quashed. en-us Thu, 10 Oct 2002 00:00:00 +0530 Fri, 19 Dec 2025 17:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=12315 Reopening under ss. 147/148 beyond four years was challenged on the ground that the Assessing Officer lacked valid "reasons to believe" and that sanction under s. 151 was mechanical. The HC held that s. 148(2) requires reasons to be recorded on tangible material showing escapement of income; mere suspicion about a loan's genuineness, without any information on record linking the assessee to a bogus transaction, cannot found jurisdiction to reopen. Consequently, the notice was invalid. The HC further held that the approving authority under s. 151 must independently apply mind to the recorded reasons; routine approval breaches the statutory safeguard, vitiating the notice. The writ was allowed and the impugned s. 148 notice was quashed. Case-Laws Income Tax Thu, 10 Oct 2002 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=12315