https://www.taxtmi.com/caselaws?id=785372 Reassessment under the Income-tax Act cannot be initiated on the same seized digital material that was already used in earlier assessment proceedings and examined in appeal. Here, the reopening was based on a WhatsApp image that had formed the foundation of a section 153C addition, and that addition had already been deleted in appeal. Because the material had been fully considered and adjudicated earlier, the same facts could not support another round of reassessment without a fresh and independent basis. The impugned reopening notice and order were therefore unsustainable. en-us Mon, 12 Jan 2026 00:00:00 +0530 Thu, 22 Jan 2026 08:41:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785372 Reassessment under the Income-tax Act cannot be initiated on the same seized digital material that was already used in earlier assessment proceedings and examined in appeal. Here, the reopening was based on a WhatsApp image that had formed the foundation of a section 153C addition, and that addition had already been deleted in appeal. Because the material had been fully considered and adjudicated earlier, the same facts could not support another round of reassessment without a fresh and independent basis. The impugned reopening notice and order were therefore unsustainable. Case-Laws Income Tax Mon, 12 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785372