https://www.taxtmi.com/caselaws?id=466306 Recording reasons for reopening an assessment before any return is on record cannot supply a reason to believe that income has escaped assessment based on a claimed exemption; because no claim existed when reasons were recorded, the AO and sanctioning authority failed to apply their minds and could not lawfully form the requisite belief. Relying on prior precedents, the commentary concludes that reasons recorded in such pre-filing circumstances are based on incorrect factual understanding and are legally defective, with the operative effect that the reopening is quashed and the appeal succeeds. en-us Fri, 28 Feb 2025 00:00:00 +0530 Sun, 01 Feb 2026 19:07:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466306 Recording reasons for reopening an assessment before any return is on record cannot supply a reason to believe that income has escaped assessment based on a claimed exemption; because no claim existed when reasons were recorded, the AO and sanctioning authority failed to apply their minds and could not lawfully form the requisite belief. Relying on prior precedents, the commentary concludes that reasons recorded in such pre-filing circumstances are based on incorrect factual understanding and are legally defective, with the operative effect that the reopening is quashed and the appeal succeeds. Case-Laws Income Tax Fri, 28 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466306