https://www.taxtmi.com/caselaws?id=784152 Reassessment under ss. 147/148 based solely on Investigation Wing inputs, without any seized material or independent enquiry, was held to be founded on mere suspicion and "borrowed satisfaction"; for an unabated AY, the AO ought to have proceeded, if at all, under s. 153C upon receipt of incriminating material. As the AO neither investigated the assessee's confirmations nor possessed tangible material to form "reason to believe", jurisdiction to reopen was absent and the proceedings were void ab initio; the reassessment was quashed and the appeal allowed. The first appellate authority's rejection of evidence and forensic doubts could not cure the foundational lack of jurisdiction, and the Tribunal therefore declined to examine merits, including forfeiture and ad hoc disallowances. en-us Fri, 24 Oct 2025 00:00:00 +0530 Tue, 30 Dec 2025 09:27:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784152 Reassessment under ss. 147/148 based solely on Investigation Wing inputs, without any seized material or independent enquiry, was held to be founded on mere suspicion and "borrowed satisfaction"; for an unabated AY, the AO ought to have proceeded, if at all, under s. 153C upon receipt of incriminating material. As the AO neither investigated the assessee's confirmations nor possessed tangible material to form "reason to believe", jurisdiction to reopen was absent and the proceedings were void ab initio; the reassessment was quashed and the appeal allowed. The first appellate authority's rejection of evidence and forensic doubts could not cure the foundational lack of jurisdiction, and the Tribunal therefore declined to examine merits, including forfeiture and ad hoc disallowances. Case-Laws Income Tax Fri, 24 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784152