https://www.taxtmi.com/caselaws?id=752172 HC held that reopening assessment under s.147/148 was without jurisdiction and quashed the notice. The court found the s.142(1) notice and the taxpayer's reply showed the notional guarantee commission claim had been considered by the AO, and that mere audit party objections did not furnish fresh material to form a reason to believe income escaped assessment. As no independent material supported reopening, the reassessment notice was set aside and the rule made absolute. en-us Mon, 15 Apr 2024 00:00:00 +0530 Mon, 01 Sep 2025 10:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752172 HC held that reopening assessment under s.147/148 was without jurisdiction and quashed the notice. The court found the s.142(1) notice and the taxpayer's reply showed the notional guarantee commission claim had been considered by the AO, and that mere audit party objections did not furnish fresh material to form a reason to believe income escaped assessment. As no independent material supported reopening, the reassessment notice was set aside and the rule made absolute. Case-Laws Income Tax Mon, 15 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752172