https://www.taxtmi.com/caselaws?id=785281 Validity of reopening assessments in third-party (non-searched) cases requires a clear application of mind and specific linkage between the predicate search and the non-searched person; where the notice under section 148 merely conflates searched and non-searched persons and fails to explain how a referenced search relates to the notice, the notice is procedurally defective and vulnerable to challenge. The document emphasises that cursory or casual issuance of reopening notices without articulating factual nexus renders reassessment notices infirm and the corresponding ground sustainable. en-us Wed, 17 Dec 2025 00:00:00 +0530 Wed, 21 Jan 2026 08:41:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785281 Validity of reopening assessments in third-party (non-searched) cases requires a clear application of mind and specific linkage between the predicate search and the non-searched person; where the notice under section 148 merely conflates searched and non-searched persons and fails to explain how a referenced search relates to the notice, the notice is procedurally defective and vulnerable to challenge. The document emphasises that cursory or casual issuance of reopening notices without articulating factual nexus renders reassessment notices infirm and the corresponding ground sustainable. Case-Laws Income Tax Wed, 17 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785281