https://www.taxtmi.com/caselaws?id=769064 ITAT Chandigarh quashed reassessment notice under section 148 for lack of valid jurisdiction. AO failed to establish reason to believe income escaped assessment, merely relying on Investigation Wing report without independent inquiry or establishing nexus with assessee. Reasons recorded were generic without tangible material or specific failure to disclose material facts. AO mechanically issued notice on limitation's last date without proper examination. Court held both conditions under section 147 must be satisfied cumulatively - reason to believe income escaped and failure to fully disclose material facts. Reassessment proceedings set aside in assessee's favor. en-us Thu, 27 Feb 2025 00:00:00 +0530 Thu, 17 Apr 2025 14:31:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=769064 ITAT Chandigarh quashed reassessment notice under section 148 for lack of valid jurisdiction. AO failed to establish reason to believe income escaped assessment, merely relying on Investigation Wing report without independent inquiry or establishing nexus with assessee. Reasons recorded were generic without tangible material or specific failure to disclose material facts. AO mechanically issued notice on limitation's last date without proper examination. Court held both conditions under section 147 must be satisfied cumulatively - reason to believe income escaped and failure to fully disclose material facts. Reassessment proceedings set aside in assessee's favor. Case-Laws Income Tax Thu, 27 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769064