https://www.taxtmi.com/caselaws?id=786788 Reopening an assessment under section 147/148 was held invalid where the reasons recorded referred to a different financial year than the year reopened and the Assessing Officer merely reproduced investigation material without independent application of mind. Applying the principle that reasons to believe must rest on tangible material and an AO's own concluded belief (not borrowed satisfaction), the Tribunal found the recorded reasons defective and the action amounted to a fishing inquiry; accordingly the reopening and resulting assessment order were quashed and the appeal allowed for the assessee. en-us Tue, 17 Feb 2026 00:00:00 +0530 Thu, 19 Feb 2026 07:58:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786788 Reopening an assessment under section 147/148 was held invalid where the reasons recorded referred to a different financial year than the year reopened and the Assessing Officer merely reproduced investigation material without independent application of mind. Applying the principle that reasons to believe must rest on tangible material and an AO's own concluded belief (not borrowed satisfaction), the Tribunal found the recorded reasons defective and the action amounted to a fishing inquiry; accordingly the reopening and resulting assessment order were quashed and the appeal allowed for the assessee. Case-Laws Income Tax Tue, 17 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786788