https://www.taxtmi.com/caselaws?id=789402 Reassessment under section 147 requires tangible material and a rational nexus with escapement of income; it cannot rest on borrowed investigation information or a mechanical, unverified acceptance of third-party material. Where the original assessment was completed under section 143(3) and reopening was initiated after four years, the Revenue had to also show a specific failure by the assessee to fully and truly disclose all material facts. The recorded reasons did not independently verify the information, did not establish the nature of the transaction, and amounted to a fishing and roving enquiry. As the transaction had already been disclosed in the original proceedings, the jurisdictional conditions for reopening were not met and the reassessment was quashed. en-us Mon, 23 Mar 2026 00:00:00 +0530 Wed, 08 Apr 2026 08:56:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789402 Reassessment under section 147 requires tangible material and a rational nexus with escapement of income; it cannot rest on borrowed investigation information or a mechanical, unverified acceptance of third-party material. Where the original assessment was completed under section 143(3) and reopening was initiated after four years, the Revenue had to also show a specific failure by the assessee to fully and truly disclose all material facts. The recorded reasons did not independently verify the information, did not establish the nature of the transaction, and amounted to a fishing and roving enquiry. As the transaction had already been disclosed in the original proceedings, the jurisdictional conditions for reopening were not met and the reassessment was quashed. Case-Laws Income Tax Mon, 23 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789402