https://www.taxtmi.com/caselaws?id=465266 HC quashed reassessment proceedings initiated u/s 147 where notice u/s 148A(b) and the accompanying dissemination note alleged a "fictitious loan," although the Department subsequently sought to justify reopening on the basis of "fictitious long term capital gain." HC held that reasons to believe must be clearly and correctly articulated in the notice, and the allegation must be precise to afford the assessee a fair opportunity to respond as mandated by s.148A(b). Vague or incorrect allegations vitiate the jurisdiction to reopen. Consequently, the reassessment notice and subsequent proceedings were set aside, with relief granted to the assessee. en-us Fri, 05 Aug 2022 00:00:00 +0530 Fri, 12 Dec 2025 20:19:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465266 HC quashed reassessment proceedings initiated u/s 147 where notice u/s 148A(b) and the accompanying dissemination note alleged a "fictitious loan," although the Department subsequently sought to justify reopening on the basis of "fictitious long term capital gain." HC held that reasons to believe must be clearly and correctly articulated in the notice, and the allegation must be precise to afford the assessee a fair opportunity to respond as mandated by s.148A(b). Vague or incorrect allegations vitiate the jurisdiction to reopen. Consequently, the reassessment notice and subsequent proceedings were set aside, with relief granted to the assessee. Case-Laws Income Tax Fri, 05 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465266