https://www.taxtmi.com/caselaws?id=403610 Reopening of assessment requires a genuine belief that income has escaped assessment because the assessee failed to disclose material facts; that belief must follow independent application of mind and verification by the assessing officer. A mere recital that material facts were not disclosed, or a borrowed satisfaction, is insufficient to validate reassessment. An inference of undisclosed income based on conjecture about a large cash transaction, without factual verification or finding that disclosure was untrue or incomplete, does not satisfy the conditions precedent for reopening. The reassessment was therefore held invalid and decided in favour of the assessee. en-us Wed, 06 Jan 2021 00:00:00 +0530 Fri, 30 Jan 2026 18:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=403610 Reopening of assessment requires a genuine belief that income has escaped assessment because the assessee failed to disclose material facts; that belief must follow independent application of mind and verification by the assessing officer. A mere recital that material facts were not disclosed, or a borrowed satisfaction, is insufficient to validate reassessment. An inference of undisclosed income based on conjecture about a large cash transaction, without factual verification or finding that disclosure was untrue or incomplete, does not satisfy the conditions precedent for reopening. The reassessment was therefore held invalid and decided in favour of the assessee. Case-Laws Income Tax Wed, 06 Jan 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=403610