https://www.taxtmi.com/caselaws?id=433407 Reassessment under sections 147 and 148 cannot be sustained unless the recorded reasons disclose tangible material and a live nexus between that material and a reasoned belief that identifiable income has escaped assessment. Where the reasons rely on vague allegations of illegal mining and third-party reports but do not quantify the alleged escapement or show any actionable finding linking the material to the assessee, the reopening is treated as a fishing enquiry. On that basis, the reassessment notice was invalid and the proceedings were quashed. en-us Tue, 17 Jan 2023 00:00:00 +0530 Wed, 05 Apr 2023 16:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=433407 Reassessment under sections 147 and 148 cannot be sustained unless the recorded reasons disclose tangible material and a live nexus between that material and a reasoned belief that identifiable income has escaped assessment. Where the reasons rely on vague allegations of illegal mining and third-party reports but do not quantify the alleged escapement or show any actionable finding linking the material to the assessee, the reopening is treated as a fishing enquiry. On that basis, the reassessment notice was invalid and the proceedings were quashed. Case-Laws Income Tax Tue, 17 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=433407