https://www.taxtmi.com/caselaws?id=784872 Validity of reopening of assessment was examined with emphasis on the requirement of tangible material establishing a direct nexus to form a reason to believe; absence of such rational connection and arbitrary change of grounds violated principles of natural justice, leading to interference under writ jurisdiction. The procedural pre-conditions for invoking reassessment were held mandatory and the impugned order under Section 148A(3) and the consequent reopening notice under Section 148 were set aside for failure to satisfy the statutory drill and denial of opportunity to meet altered grounds. en-us Fri, 09 Jan 2026 00:00:00 +0530 Tue, 13 Jan 2026 08:29:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784872 Validity of reopening of assessment was examined with emphasis on the requirement of tangible material establishing a direct nexus to form a reason to believe; absence of such rational connection and arbitrary change of grounds violated principles of natural justice, leading to interference under writ jurisdiction. The procedural pre-conditions for invoking reassessment were held mandatory and the impugned order under Section 148A(3) and the consequent reopening notice under Section 148 were set aside for failure to satisfy the statutory drill and denial of opportunity to meet altered grounds. Case-Laws Income Tax Fri, 09 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784872