https://www.taxtmi.com/caselaws?id=782151 Reopening of assessment was challenged on the ground that the AO's recorded reasons lacked independent application of mind and were merely a reproduction of an investigation report alleging bogus LTCG and accommodation entries through alleged shell entities. The HC held that such reasons do not satisfy the statutory requirement of "reason to believe" because the AO must form an independent belief on relevant material; consequently, the reassessment and related additions were unsustainable. The SC dismissed the revenue's SLP both on delay and on merits, thereby affirming the HC's quashing of the reopening and consequential additions. en-us Fri, 21 Nov 2025 00:00:00 +0530 Mon, 22 Dec 2025 10:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782151 Reopening of assessment was challenged on the ground that the AO's recorded reasons lacked independent application of mind and were merely a reproduction of an investigation report alleging bogus LTCG and accommodation entries through alleged shell entities. The HC held that such reasons do not satisfy the statutory requirement of "reason to believe" because the AO must form an independent belief on relevant material; consequently, the reassessment and related additions were unsustainable. The SC dismissed the revenue's SLP both on delay and on merits, thereby affirming the HC's quashing of the reopening and consequential additions. Case-Laws Income Tax Fri, 21 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782151