https://www.taxtmi.com/caselaws?id=780010 HC dismissed challenge to reopening of assessment under section 147, upholding the impugned order where no jurisdictional plea was raised. Relying on Supreme Court precedent, the court held that courts may review only the reasonableness (Wednesbury standard) of the recorded belief and not re-appraise the sufficiency of the reasons; formation of belief is administrative and must be bona fide, based on relevant material. Extraneous considerations vitiate the belief. Pursuant to the Finance Act, 2017 explanation, reasons to believe need not be disclosed to the assessee or appellate authorities. en-us Mon, 06 Oct 2025 00:00:00 +0530 Thu, 16 Oct 2025 08:31:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780010 HC dismissed challenge to reopening of assessment under section 147, upholding the impugned order where no jurisdictional plea was raised. Relying on Supreme Court precedent, the court held that courts may review only the reasonableness (Wednesbury standard) of the recorded belief and not re-appraise the sufficiency of the reasons; formation of belief is administrative and must be bona fide, based on relevant material. Extraneous considerations vitiate the belief. Pursuant to the Finance Act, 2017 explanation, reasons to believe need not be disclosed to the assessee or appellate authorities. Case-Laws Income Tax Mon, 06 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780010