https://www.taxtmi.com/caselaws?id=465834 Reopening under ss. 147/148 was upheld because the AO had tangible material in the form of an additional income declaration made before the ITSC, satisfying the "reason to believe" standard (not mere suspicion) and maintaining a live nexus between material and belief; the reassessment initiation was therefore valid. However, additions based solely on the s. 245C(1) settlement application were deleted since the application was not admitted and there was no direct or corroborative evidence that the taxpayer actually earned undisclosed income; mere disclosure to meet ITSC maintainability could not, by itself, justify an addition, and prior ITAT orders in the same taxpayer's case required reversal of the AO/CIT(A) on merits. en-us Tue, 27 Feb 2018 00:00:00 +0530 Sun, 11 Jan 2026 09:19:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465834 Reopening under ss. 147/148 was upheld because the AO had tangible material in the form of an additional income declaration made before the ITSC, satisfying the "reason to believe" standard (not mere suspicion) and maintaining a live nexus between material and belief; the reassessment initiation was therefore valid. However, additions based solely on the s. 245C(1) settlement application were deleted since the application was not admitted and there was no direct or corroborative evidence that the taxpayer actually earned undisclosed income; mere disclosure to meet ITSC maintainability could not, by itself, justify an addition, and prior ITAT orders in the same taxpayer's case required reversal of the AO/CIT(A) on merits. Case-Laws Income Tax Tue, 27 Feb 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465834