https://www.taxtmi.com/caselaws?id=784597 The dominant issue was whether reopening under s.147/s.148 was valid on the statutory "reason to believe" standard. The Tribunal held the recorded reasons reflected borrowed satisfaction and factual non-application of mind, including an incorrect premise that exemption under s.10(38) was claimed when no such claim existed, and absence of any primary enquiry before issuing notice. It further held reassessment cannot be invoked for mere verification or a roving enquiry, consistent with jurisdictional HC authority that reopening to "verify details" is impermissible. Consequently, the reopening was held bad in law and the reassessment order was quashed, allowing the appeal. en-us Mon, 24 Nov 2025 00:00:00 +0530 Thu, 08 Jan 2026 08:22:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784597 The dominant issue was whether reopening under s.147/s.148 was valid on the statutory "reason to believe" standard. The Tribunal held the recorded reasons reflected borrowed satisfaction and factual non-application of mind, including an incorrect premise that exemption under s.10(38) was claimed when no such claim existed, and absence of any primary enquiry before issuing notice. It further held reassessment cannot be invoked for mere verification or a roving enquiry, consistent with jurisdictional HC authority that reopening to "verify details" is impermissible. Consequently, the reopening was held bad in law and the reassessment order was quashed, allowing the appeal. Case-Laws Income Tax Mon, 24 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784597