https://www.taxtmi.com/caselaws?id=466767 Issue concerns validity of reopening assessments under Section 147/148 where the Assessing Officer relied on an Investigation Wing report without independent application of mind. The legal principle applied requires the AO to possess relevant, credible material and to record an independent formation of belief showing a live nexus between that material and escaped income; mere suspicion, rumour or unverified investigation reports are insufficient. Applying that test, the reassessment and notice were invalidated because the AO failed to verify the report, did not demonstrate independent application of mind, and did not establish a live link between material and belief; appeal allowed for the assessee. en-us Fri, 14 Nov 2025 00:00:00 +0530 Wed, 18 Feb 2026 13:13:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466767 Issue concerns validity of reopening assessments under Section 147/148 where the Assessing Officer relied on an Investigation Wing report without independent application of mind. The legal principle applied requires the AO to possess relevant, credible material and to record an independent formation of belief showing a live nexus between that material and escaped income; mere suspicion, rumour or unverified investigation reports are insufficient. Applying that test, the reassessment and notice were invalidated because the AO failed to verify the report, did not demonstrate independent application of mind, and did not establish a live link between material and belief; appeal allowed for the assessee. Case-Laws Income Tax Fri, 14 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466767