https://www.taxtmi.com/caselaws?id=784621 The dominant issue was the validity of reassessment initiation under s.147 on the "reason to believe" standard. The HC held that the AO had territorial jurisdiction to issue the notice despite the assessee's name change, since it did not alter territorial jurisdiction and AOs within the same territory could act; consequently, the jurisdictional challenge failed. However, the HC found the reopening unsustainable because the recorded reasons lacked essential particulars (nature and date of transaction) and failed to show a live nexus between the information relied upon and the assessee's audited books, so the AO could not form even a prima facie belief of income escaping assessment; accordingly, the notice was quashed. The SC refused to interfere and dismissed the SLP. en-us Tue, 06 Jan 2026 00:00:00 +0530 Thu, 08 Jan 2026 08:22:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784621 The dominant issue was the validity of reassessment initiation under s.147 on the "reason to believe" standard. The HC held that the AO had territorial jurisdiction to issue the notice despite the assessee's name change, since it did not alter territorial jurisdiction and AOs within the same territory could act; consequently, the jurisdictional challenge failed. However, the HC found the reopening unsustainable because the recorded reasons lacked essential particulars (nature and date of transaction) and failed to show a live nexus between the information relied upon and the assessee's audited books, so the AO could not form even a prima facie belief of income escaping assessment; accordingly, the notice was quashed. The SC refused to interfere and dismissed the SLP. Case-Laws Income Tax Tue, 06 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784621