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    <title>2016 (5) TMI 1588 - ITAT CHANDIGARH</title>
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    <description>Reassessment under section 147 requires recorded reasons based on relevant material with a live nexus to the belief that income has escaped assessment. The recorded reasons here were invalid because they incorrectly attributed the complaint to the assessee, when it was made by the assessee&#039;s daughter, and relied on a section 161 CrPC statement that was neither on oath nor tested by cross-examination or independent corroboration. On that material, the belief was treated as suspicion rather than legally sufficient grounds, showing lack of application of mind and absence of jurisdiction to reopen; the reopening was therefore invalid and the reassessment was quashed.</description>
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    <pubDate>Thu, 19 May 2016 00:00:00 +0530</pubDate>
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      <title>2016 (5) TMI 1588 - ITAT CHANDIGARH</title>
      <link>https://www.taxtmi.com/caselaws?id=303790</link>
      <description>Reassessment under section 147 requires recorded reasons based on relevant material with a live nexus to the belief that income has escaped assessment. The recorded reasons here were invalid because they incorrectly attributed the complaint to the assessee, when it was made by the assessee&#039;s daughter, and relied on a section 161 CrPC statement that was neither on oath nor tested by cross-examination or independent corroboration. On that material, the belief was treated as suspicion rather than legally sufficient grounds, showing lack of application of mind and absence of jurisdiction to reopen; the reopening was therefore invalid and the reassessment was quashed.</description>
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      <pubDate>Thu, 19 May 2016 00:00:00 +0530</pubDate>
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