https://www.taxtmi.com/highlights?id=96631 Reopening of assessment under the income tax code was challenged on the ground that the reasons recorded relied solely on the claim of interest deduction made without a certificate. The court held that validity of reassessment must be tested only by the reasons recorded; material asserted only in an affidavit cannot supply a basis. The absence of a certificate was not a valid ground where statutes did not require filing it in the assessed facts, and precedent distinguishing cases where expenditure related to taxfree income was disallowable was applied. Consequence: reassessment jurisdiction was invalidated and the appeal by the assessee allowed. en-us Thu, 05 Feb 2026 09:16:12 +0530 Thu, 05 Feb 2026 09:16:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=96631 Reopening of assessment under the income tax code was challenged on the ground that the reasons recorded relied solely on the claim of interest deduction made without a certificate. The court held that validity of reassessment must be tested only by the reasons recorded; material asserted only in an affidavit cannot supply a basis. The absence of a certificate was not a valid ground where statutes did not require filing it in the assessed facts, and precedent distinguishing cases where expenditure related to taxfree income was disallowable was applied. Consequence: reassessment jurisdiction was invalidated and the appeal by the assessee allowed. Highlights Income Tax Thu, 05 Feb 2026 09:16:12 +0530 https://www.taxtmi.com/highlights?id=96631