https://www.taxtmi.com/caselaws?id=446218 The Gujarat HC held that reopening of assessment was invalid where the AO relied solely on material from the original assessment without fresh evidence. The petitioner, selected for CASS scrutiny regarding low income versus high loans/investments and interest expenses under section 14A, had disclosed all material facts during original assessment. The court found the AO lacked jurisdiction to reopen based merely on assumptions that the assessee should have charged 12% interest on advances, as this inference lacked supporting material. The reopening was deemed invalid absent any basis beyond presumptions to conclude income had escaped assessment. Petition allowed. en-us Mon, 11 Sep 2023 00:00:00 +0530 Mon, 16 Feb 2026 11:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446218 The Gujarat HC held that reopening of assessment was invalid where the AO relied solely on material from the original assessment without fresh evidence. The petitioner, selected for CASS scrutiny regarding low income versus high loans/investments and interest expenses under section 14A, had disclosed all material facts during original assessment. The court found the AO lacked jurisdiction to reopen based merely on assumptions that the assessee should have charged 12% interest on advances, as this inference lacked supporting material. The reopening was deemed invalid absent any basis beyond presumptions to conclude income had escaped assessment. Petition allowed. Case-Laws Income Tax Mon, 11 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446218