https://www.taxtmi.com/caselaws?id=787513 Reassessment initiated under sections 147/148 was challenged on grounds of borrowed satisfaction and lack of jurisdiction; the analysis emphasises that reopening after four years requires a recorded satisfaction that the assessee failed to disclose all material facts, independent verification of investigation-sourced information, and that reassessment cannot rest on a mere change of opinion. The notice was issued by an officer without jurisdiction and without a valid transfer of proceedings, rendering the reopening and consequential reassessment order invalid and resulting in quashal of the reassessment. en-us Wed, 18 Feb 2026 00:00:00 +0530 Thu, 05 Mar 2026 14:13:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787513 Reassessment initiated under sections 147/148 was challenged on grounds of borrowed satisfaction and lack of jurisdiction; the analysis emphasises that reopening after four years requires a recorded satisfaction that the assessee failed to disclose all material facts, independent verification of investigation-sourced information, and that reassessment cannot rest on a mere change of opinion. The notice was issued by an officer without jurisdiction and without a valid transfer of proceedings, rendering the reopening and consequential reassessment order invalid and resulting in quashal of the reassessment. Case-Laws Income Tax Wed, 18 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787513