https://www.taxtmi.com/highlights?id=96000 The central issue was the validity of reopening assessment under Section 147 read with Sections 148 and 148A: the Court held that reopening requires "tangible material" and a rational connection between that material and the Assessing Officer's opinion of escapement, following Lakhmani Mewal Das; absent such nexus the action is unlawful. The Court found arbitrariness in changing the ground of reopening from the show-cause notice and a consequent breach of natural justice, and emphasized that Section 147 operates only after completion of the Section 148/148A drill. The order under Section 148A(3) and the Section 148 notice for AY 2019-20 were set aside. - HC en-us Tue, 13 Jan 2026 12:09:56 +0530 Tue, 13 Jan 2026 12:09:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=96000 The central issue was the validity of reopening assessment under Section 147 read with Sections 148 and 148A: the Court held that reopening requires "tangible material" and a rational connection between that material and the Assessing Officer's opinion of escapement, following Lakhmani Mewal Das; absent such nexus the action is unlawful. The Court found arbitrariness in changing the ground of reopening from the show-cause notice and a consequent breach of natural justice, and emphasized that Section 147 operates only after completion of the Section 148/148A drill. The order under Section 148A(3) and the Section 148 notice for AY 2019-20 were set aside. - HC Highlights Income Tax Tue, 13 Jan 2026 12:09:56 +0530 https://www.taxtmi.com/highlights?id=96000