https://www.taxtmi.com/caselaws?id=466457 Reopening under section 147 requires material that rationally supports a belief that income has escaped assessment. Where the Assessing Officer relied only on excise department findings alleging clandestine sales and suppression of turnover, without independent verification or corroborative evidence, the reopening could not stand once those findings were reversed in the assessee's own case. The very basis for the belief then ceased to have legal foundation, so the reassessment under sections 147 and 148 was invalid and the consequential additions became infructuous. en-us Fri, 10 May 2024 00:00:00 +0530 Mon, 09 Feb 2026 11:10:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466457 Reopening under section 147 requires material that rationally supports a belief that income has escaped assessment. Where the Assessing Officer relied only on excise department findings alleging clandestine sales and suppression of turnover, without independent verification or corroborative evidence, the reopening could not stand once those findings were reversed in the assessee's own case. The very basis for the belief then ceased to have legal foundation, so the reassessment under sections 147 and 148 was invalid and the consequential additions became infructuous. Case-Laws Income Tax Fri, 10 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466457