https://www.taxtmi.com/caselaws?id=783692 Reopening under ss. 148/149/151 was challenged on the ground that the AO and the competent authority repeatedly re-presented and reconsidered the proposal for sanction after an initial rejection. Applying the principle that the Act does not confer any power of review on the AO or sanctioning authority, the HC held that repeated presentation/re-presentation was without jurisdiction and the subsequent sanction under s. 151 was void; the reassessment proceedings were therefore invalidated. On merits of "reason to believe", the HC found the loose papers were misread, contained references to multiple persons, and lacked corroborative material linking the assessee to any quid pro quo for contracts awarded by an independent PSU; the recorded reasons at best raised suspicion, not belief, and the reopening was quashed. en-us Wed, 17 Dec 2025 00:00:00 +0530 Tue, 02 Jun 2026 18:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783692 Reopening under ss. 148/149/151 was challenged on the ground that the AO and the competent authority repeatedly re-presented and reconsidered the proposal for sanction after an initial rejection. Applying the principle that the Act does not confer any power of review on the AO or sanctioning authority, the HC held that repeated presentation/re-presentation was without jurisdiction and the subsequent sanction under s. 151 was void; the reassessment proceedings were therefore invalidated. On merits of "reason to believe", the HC found the loose papers were misread, contained references to multiple persons, and lacked corroborative material linking the assessee to any quid pro quo for contracts awarded by an independent PSU; the recorded reasons at best raised suspicion, not belief, and the reopening was quashed. Case-Laws Income Tax Wed, 17 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783692