https://www.taxtmi.com/caselaws?id=789102 Reassessment was invalid because the recorded reasons and sanction under section 151 proceeded on the mistaken premise that the assessee had not filed a return and had not disclosed the capital transaction. The return and computation showing disclosure of the property transaction were already on record, so the jurisdiction assumed for reopening was vitiated by incorrect foundational facts. The defect went to the root of the reassessment and no remand was required because the relevant material was already available. The reassessment was held void, and the jurisdictional challenge succeeded in favour of the assessee. en-us Fri, 20 Feb 2026 00:00:00 +0530 Fri, 03 Apr 2026 08:49:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789102 Reassessment was invalid because the recorded reasons and sanction under section 151 proceeded on the mistaken premise that the assessee had not filed a return and had not disclosed the capital transaction. The return and computation showing disclosure of the property transaction were already on record, so the jurisdiction assumed for reopening was vitiated by incorrect foundational facts. The defect went to the root of the reassessment and no remand was required because the relevant material was already available. The reassessment was held void, and the jurisdictional challenge succeeded in favour of the assessee. Case-Laws Income Tax Fri, 20 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789102