https://www.taxtmi.com/caselaws?id=787042 The petition challenged a notice under section 148 and a reassessment order for AY 2011 12 on grounds that reopening requires tangible material and a live link to form a reason to believe, and cannot rest on mere change of opinion; limitation rules for reopening were also considered. The court applied settled tests requiring tangible material and a contemporaneous connection between material and belief, found the recorded reasons did not disclose new tangible material or a live link and amounted to change of opinion, and held the notice and reassessment order illegal and without jurisdiction, quashing them in favour of the assessee. en-us Tue, 03 Feb 2026 00:00:00 +0530 Wed, 25 Feb 2026 07:26:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787042 The petition challenged a notice under section 148 and a reassessment order for AY 2011 12 on grounds that reopening requires tangible material and a live link to form a reason to believe, and cannot rest on mere change of opinion; limitation rules for reopening were also considered. The court applied settled tests requiring tangible material and a contemporaneous connection between material and belief, found the recorded reasons did not disclose new tangible material or a live link and amounted to change of opinion, and held the notice and reassessment order illegal and without jurisdiction, quashing them in favour of the assessee. Case-Laws Income Tax Tue, 03 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787042