https://www.taxtmi.com/caselaws?id=785052 Reopening of assessment examined where AO relied on AIR information alleging nondisclosure of PAN and absence of return. The basis for reopening assumed no return was filed, but assessment record and taxpayer's acknowledgment showed a return was filed, rendering the stated reasons factually erroneous. Because reasons to believe are foundational to reopening proceedings, reliance on incorrect factual assumptions made the reasons invalid and vitiated the consequent proceedings; the resultant assessment framed on that basis was set aside. The taxpayer's appeal against the reopened assessment was allowed. en-us Wed, 26 Nov 2025 00:00:00 +0530 Fri, 16 Jan 2026 08:03:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785052 Reopening of assessment examined where AO relied on AIR information alleging nondisclosure of PAN and absence of return. The basis for reopening assumed no return was filed, but assessment record and taxpayer's acknowledgment showed a return was filed, rendering the stated reasons factually erroneous. Because reasons to believe are foundational to reopening proceedings, reliance on incorrect factual assumptions made the reasons invalid and vitiated the consequent proceedings; the resultant assessment framed on that basis was set aside. The taxpayer's appeal against the reopened assessment was allowed. Case-Laws Income Tax Wed, 26 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785052