https://www.taxtmi.com/caselaws?id=786066 Reopening of assessment requires a recorded 'reason to believe' supported by tangible material linking transactions to escapement of income; mere receipt of funds from a third party and an unsubstantiated suspicion do not suffice. The AO's reasons were held scanty, vague and based on subjective opinion without reference to documents, nexus or evidence; the AO failed to make reasonable enquiries to convert suspicion into belief. Consequently, the reopening under section 147 was invalidated and the challenge succeeded for the assessee, as the AO's action amounted to a prohibited roving inquiry. en-us Mon, 02 Feb 2026 00:00:00 +0530 Thu, 05 Feb 2026 09:16:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786066 Reopening of assessment requires a recorded 'reason to believe' supported by tangible material linking transactions to escapement of income; mere receipt of funds from a third party and an unsubstantiated suspicion do not suffice. The AO's reasons were held scanty, vague and based on subjective opinion without reference to documents, nexus or evidence; the AO failed to make reasonable enquiries to convert suspicion into belief. Consequently, the reopening under section 147 was invalidated and the challenge succeeded for the assessee, as the AO's action amounted to a prohibited roving inquiry. Case-Laws Income Tax Mon, 02 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786066