https://www.taxtmi.com/caselaws?id=785629 Reopening of assessment requires the Assessing Officer to independently record reasons to believe and not merely borrow material from an external report; here, the stated reasons were based on the Justice M.B. Shah Commission report without independent satisfaction. The Supreme Court also noted an unexplained delay of 424 days in filing the Special Leave Petition and declined interference with the High Court's order, dismissing the petition both for delay and on merits. en-us Fri, 23 Jan 2026 00:00:00 +0530 Wed, 28 Jan 2026 07:26:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785629 Reopening of assessment requires the Assessing Officer to independently record reasons to believe and not merely borrow material from an external report; here, the stated reasons were based on the Justice M.B. Shah Commission report without independent satisfaction. The Supreme Court also noted an unexplained delay of 424 days in filing the Special Leave Petition and declined interference with the High Court's order, dismissing the petition both for delay and on merits. Case-Laws Income Tax Fri, 23 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785629