https://www.taxtmi.com/caselaws?id=768078 Reassessment under section 147 was invalid where the reopening was based on the mistaken assumption that no return of income had been filed, although the record showed that a return had in fact been filed. Because the reassessment was initiated beyond four years without a proper nexus between tangible material and a valid belief of escapement of income, the jurisdiction to reopen failed. Once the reassessment was quashed, the penalty under section 271(1)(c), being consequential to that assessment, could not survive independently. en-us Fri, 28 Mar 2025 00:00:00 +0530 Mon, 31 Mar 2025 08:41:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768078 Reassessment under section 147 was invalid where the reopening was based on the mistaken assumption that no return of income had been filed, although the record showed that a return had in fact been filed. Because the reassessment was initiated beyond four years without a proper nexus between tangible material and a valid belief of escapement of income, the jurisdiction to reopen failed. Once the reassessment was quashed, the penalty under section 271(1)(c), being consequential to that assessment, could not survive independently. Case-Laws Income Tax Fri, 28 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768078