https://www.taxtmi.com/caselaws?id=13037 The dominant issue was whether a reassessment notice under s.148 could be sustained on "reason to believe" founded on a valuation report. The HC held that formation of belief is an administrative act requiring relevant, tangible material with a rational nexus to escapement; judicial review is limited to examining existence of such material and legal tenability, not sufficiency. A valuation officer's report, though opinion-based and even if obtained through a reference that later became inoperative, can still constitute "information" for s.147 purposes, akin to evidentiary use of illegally obtained material. Since the assessing authority recorded reasons relying on the valuation report to infer understatement of capital gains, the notice had a live nexus and was upheld; the writ petition was dismissed. en-us Fri, 23 Mar 2001 00:00:00 +0530 Sat, 20 Dec 2025 23:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=13037 The dominant issue was whether a reassessment notice under s.148 could be sustained on "reason to believe" founded on a valuation report. The HC held that formation of belief is an administrative act requiring relevant, tangible material with a rational nexus to escapement; judicial review is limited to examining existence of such material and legal tenability, not sufficiency. A valuation officer's report, though opinion-based and even if obtained through a reference that later became inoperative, can still constitute "information" for s.147 purposes, akin to evidentiary use of illegally obtained material. Since the assessing authority recorded reasons relying on the valuation report to infer understatement of capital gains, the notice had a live nexus and was upheld; the writ petition was dismissed. Case-Laws Income Tax Fri, 23 Mar 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=13037