https://www.taxtmi.com/caselaws?id=30440 HC held that the reassessment notice under s.148 was invalid because the AO lacked reasoned belief and material indicating the land was a capital asset under s.2(14). The recorded reasons were factual and exploratory, amounting to mere suspicion rather than a belief based on information or material; no new material had emerged after filing of the return. Concurrent findings of the CIT(A) and Tribunal that the AO had no basis for reopening were upheld, and the appeal was dismissed. en-us Fri, 08 Aug 2008 00:00:00 +0530 Fri, 15 May 2026 12:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=30440 HC held that the reassessment notice under s.148 was invalid because the AO lacked reasoned belief and material indicating the land was a capital asset under s.2(14). The recorded reasons were factual and exploratory, amounting to mere suspicion rather than a belief based on information or material; no new material had emerged after filing of the return. Concurrent findings of the CIT(A) and Tribunal that the AO had no basis for reopening were upheld, and the appeal was dismissed. Case-Laws Income Tax Fri, 08 Aug 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=30440