https://www.taxtmi.com/caselaws?id=783508 HC held that reopening of assessment under Section 147 was invalid as the jurisdictional precondition of "reason to believe" that income had escaped assessment was not satisfied. The assessee had made full and true disclosure of all material facts, including profit and loss account and detailed transactions with alleged bogus suppliers, during the original assessment. The reassessment was triggered merely because the suppliers failed to cooperate with the tax authority, amounting to a fishing and roving inquiry rather than a bona fide belief of escapement of income. HC concluded that the Assessing Officer misdirected himself in invoking Section 148 and quashed the reassessment proceedings, allowing the writ petition. en-us Tue, 09 Dec 2025 00:00:00 +0530 Tue, 16 Dec 2025 18:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783508 HC held that reopening of assessment under Section 147 was invalid as the jurisdictional precondition of "reason to believe" that income had escaped assessment was not satisfied. The assessee had made full and true disclosure of all material facts, including profit and loss account and detailed transactions with alleged bogus suppliers, during the original assessment. The reassessment was triggered merely because the suppliers failed to cooperate with the tax authority, amounting to a fishing and roving inquiry rather than a bona fide belief of escapement of income. HC concluded that the Assessing Officer misdirected himself in invoking Section 148 and quashed the reassessment proceedings, allowing the writ petition. Case-Laws Income Tax Tue, 09 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783508