https://www.taxtmi.com/caselaws?id=448681 Reopening of a completed assessment under sections 147 and 148 requires the Assessing Officer's own reason to believe, founded on tangible material with a live nexus to escapement of income, and not borrowed satisfaction from external reports or investigations. A bare assertion of independent inquiry, without disclosing what was examined or what material emerged, is insufficient to confer jurisdiction. Where the notice is issued beyond four years, the additional statutory condition of failure to disclose fully and truly all material facts must also be satisfied; that condition was not met where the alleged illegality became known only later and the assessee could not withhold a fact not then known to it. The reopening notices were invalid and quashed. en-us Fri, 19 Jan 2024 00:00:00 +0530 Fri, 12 Jul 2024 12:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448681 Reopening of a completed assessment under sections 147 and 148 requires the Assessing Officer's own reason to believe, founded on tangible material with a live nexus to escapement of income, and not borrowed satisfaction from external reports or investigations. A bare assertion of independent inquiry, without disclosing what was examined or what material emerged, is insufficient to confer jurisdiction. Where the notice is issued beyond four years, the additional statutory condition of failure to disclose fully and truly all material facts must also be satisfied; that condition was not met where the alleged illegality became known only later and the assessee could not withhold a fact not then known to it. The reopening notices were invalid and quashed. Case-Laws Income Tax Fri, 19 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448681