https://www.taxtmi.com/caselaws?id=784152 Reassessment under sections 147 and 148 was treated as invalid where the reopening rested only on Investigation Wing information from a search in another concern, without independent application of mind or tangible material showing a live nexus to escapement of income. The reasons recorded did not link any seized material directly to the assessee, and borrowed satisfaction was held insufficient to confer jurisdiction; the reassessment was therefore void ab initio. An ad hoc disallowance of expenditure was also found unsustainable because it was made on estimate without proper verification of the business character of the expenses. The reassessment additions accordingly did not survive. 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 sections 147 and 148 was treated as invalid where the reopening rested only on Investigation Wing information from a search in another concern, without independent application of mind or tangible material showing a live nexus to escapement of income. The reasons recorded did not link any seized material directly to the assessee, and borrowed satisfaction was held insufficient to confer jurisdiction; the reassessment was therefore void ab initio. An ad hoc disallowance of expenditure was also found unsustainable because it was made on estimate without proper verification of the business character of the expenses. The reassessment additions accordingly did not survive. Case-Laws Income Tax Fri, 24 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784152