https://www.taxtmi.com/caselaws?id=757912 HC held that reopening under Sections 147/148 was invalid because the AO's reasons were based solely on a DDIT/Investigating Unit letter and lacked independent application of mind or tangible material. The court emphasized that formation of a belief that income escaped assessment requires a clear nexus to concrete material, not mere suspicion or borrowed satisfaction. The AO failed to make further inquiries or gather supporting material, and no line of reasoning justified reassessment. Reassessment proceedings were set aside and the appeal decided in favour of the assessee. en-us Mon, 02 Sep 2024 00:00:00 +0530 Thu, 25 Sep 2025 10:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=757912 HC held that reopening under Sections 147/148 was invalid because the AO's reasons were based solely on a DDIT/Investigating Unit letter and lacked independent application of mind or tangible material. The court emphasized that formation of a belief that income escaped assessment requires a clear nexus to concrete material, not mere suspicion or borrowed satisfaction. The AO failed to make further inquiries or gather supporting material, and no line of reasoning justified reassessment. Reassessment proceedings were set aside and the appeal decided in favour of the assessee. Case-Laws Income Tax Mon, 02 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=757912