https://www.taxtmi.com/caselaws?id=383827 A reopening under Section 147 must rest on recorded reasons showing an independent, rationally connected basis for a live belief that income escaped assessment. The Bombay HC noted that reliance mainly on the Shah Commission report and broad export-price comparisons, without material showing undisclosed income or a suppression device, was too speculative to justify reopening. It also stated that any alleged illegality in the mining activity did not change the character of the receipts into income from other sources, nor could new grounds be added later to sustain the notices. The impugned reopening notices were therefore quashed. en-us Tue, 09 Jul 2019 00:00:00 +0530 Fri, 03 Jan 2025 17:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=383827 A reopening under Section 147 must rest on recorded reasons showing an independent, rationally connected basis for a live belief that income escaped assessment. The Bombay HC noted that reliance mainly on the Shah Commission report and broad export-price comparisons, without material showing undisclosed income or a suppression device, was too speculative to justify reopening. It also stated that any alleged illegality in the mining activity did not change the character of the receipts into income from other sources, nor could new grounds be added later to sustain the notices. The impugned reopening notices were therefore quashed. Case-Laws Income Tax Tue, 09 Jul 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=383827