https://www.taxtmi.com/caselaws?id=783820 Reopening under ss.147/148 was challenged on the ground that the AO lacked "reason to believe" that income had escaped assessment, having relied merely on an STR alleging "circuitous" related-party transactions. The HC held that reopening cannot rest on suspicion or STR findings alone absent tangible material indicating escapement, particularly where there was no finding of cash exchange or money return, the assessee had made full disclosure, and the AO neither disputed nor evaluated the documentary evidence and explanations on record. The impugned notice and order were quashed, and the assessee succeeded. en-us Tue, 16 Dec 2025 00:00:00 +0530 Tue, 23 Dec 2025 07:59:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783820 Reopening under ss.147/148 was challenged on the ground that the AO lacked "reason to believe" that income had escaped assessment, having relied merely on an STR alleging "circuitous" related-party transactions. The HC held that reopening cannot rest on suspicion or STR findings alone absent tangible material indicating escapement, particularly where there was no finding of cash exchange or money return, the assessee had made full disclosure, and the AO neither disputed nor evaluated the documentary evidence and explanations on record. The impugned notice and order were quashed, and the assessee succeeded. Case-Laws Income Tax Tue, 16 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783820