https://www.taxtmi.com/caselaws?id=780440 HC held that reopening was invalid where the AO treated portal "High Risk CRIU/VRU" data as sufficient without first conducting inquiries under s.148A(a) and then furnishing specific reasons under s.148A(b). The AO must obtain sanction, seek explanations under s.148A(a), and, only if satisfied that income escaped assessment, issue a s.148A(b) notice stating the information/reasons; notices that conflate (a) and (b) or fail to disclose reasons are bad in law. en-us Mon, 06 Oct 2025 00:00:00 +0530 Mon, 11 May 2026 12:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780440 HC held that reopening was invalid where the AO treated portal "High Risk CRIU/VRU" data as sufficient without first conducting inquiries under s.148A(a) and then furnishing specific reasons under s.148A(b). The AO must obtain sanction, seek explanations under s.148A(a), and, only if satisfied that income escaped assessment, issue a s.148A(b) notice stating the information/reasons; notices that conflate (a) and (b) or fail to disclose reasons are bad in law. Case-Laws Income Tax Mon, 06 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780440