https://www.taxtmi.com/caselaws?id=435234 The dominant issue was whether reassessment under ss. 147/148 could be initiated on "reason to believe" based merely on third-party portal information alleging bogus LTCG. The HC held that the AO formed no independent nexus between the assessee and the alleged transactions, failed to verify the return and disclosed LTCG particulars, and ignored documentary material supporting genuineness (exchange contract notes, demat records, regulator confirmations, and banking trail). As the recorded reasons reflected suspicion rather than tangible material, and no undisclosed income was shown to have escaped assessment, the notice issued beyond limitation was invalid; the reassessment notice and consequential action were set aside in favour of the assessee. en-us Mon, 13 Mar 2023 00:00:00 +0530 Fri, 02 Jan 2026 10:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=435234 The dominant issue was whether reassessment under ss. 147/148 could be initiated on "reason to believe" based merely on third-party portal information alleging bogus LTCG. The HC held that the AO formed no independent nexus between the assessee and the alleged transactions, failed to verify the return and disclosed LTCG particulars, and ignored documentary material supporting genuineness (exchange contract notes, demat records, regulator confirmations, and banking trail). As the recorded reasons reflected suspicion rather than tangible material, and no undisclosed income was shown to have escaped assessment, the notice issued beyond limitation was invalid; the reassessment notice and consequential action were set aside in favour of the assessee. Case-Laws Income Tax Mon, 13 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=435234