https://www.taxtmi.com/caselaws?id=784619 Validity of reassessment reopening under s.147 turned on whether the AO had lawful "reasons to believe" and complied with jurisdictional prerequisites. The HC held that the recorded reasons were mechanical, merely reproducing information from another authority based on a third-party survey/search, without linking any specific transaction to the assessee and without supplying the relied-upon material or properly considering objections; in the absence of assessee-specific incriminating material, the AO lacked jurisdiction to issue the reopening notice, and the notice was quashed. The SC found no ground to interfere under Art. 136 and dismissed the SLP, leaving the HC decision undisturbed. 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=784619 Validity of reassessment reopening under s.147 turned on whether the AO had lawful "reasons to believe" and complied with jurisdictional prerequisites. The HC held that the recorded reasons were mechanical, merely reproducing information from another authority based on a third-party survey/search, without linking any specific transaction to the assessee and without supplying the relied-upon material or properly considering objections; in the absence of assessee-specific incriminating material, the AO lacked jurisdiction to issue the reopening notice, and the notice was quashed. The SC found no ground to interfere under Art. 136 and dismissed the SLP, leaving the HC decision undisturbed. Case-Laws Income Tax Tue, 06 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784619