https://www.taxtmi.com/caselaws?id=778040 Reopening of assessment under s.147 was found to be based on mechanically formed "reasons to believe" lacking tangible material and application of mind; the purported basis misstated the section under which assessment was framed and misidentified precedent, rendering the reassessment unsustainable. The SC agreed with the HC principle requiring tangible material to infer escapement of income and effectively ruled in favour of the assessee on merits. However, the Special Leave Petition was dismissed for failure to condone a 445-day delay, so relief was denied on procedural grounds. en-us Thu, 04 Sep 2025 00:00:00 +0530 Tue, 09 Sep 2025 08:38:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=778040 Reopening of assessment under s.147 was found to be based on mechanically formed "reasons to believe" lacking tangible material and application of mind; the purported basis misstated the section under which assessment was framed and misidentified precedent, rendering the reassessment unsustainable. The SC agreed with the HC principle requiring tangible material to infer escapement of income and effectively ruled in favour of the assessee on merits. However, the Special Leave Petition was dismissed for failure to condone a 445-day delay, so relief was denied on procedural grounds. Case-Laws Income Tax Thu, 04 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=778040