https://www.taxtmi.com/highlights?id=98820 Reassessment under Section 148 requires prima facie material showing a live link between the seized material and alleged income escaping assessment. The High Court held that vague, non-specific loose papers referring only to survey numbers, a rate and a third person's name, without the assessee's name or any nexus to her, could not justify reopening. The expressions "relates to" and "pertains to" in Explanation 2 to Section 148 cannot be applied in isolation; the Revenue must assess the material against surrounding circumstances and record prima facie relevancy. As the information lacked that connection, the notice and consequential reopening were quashed. en-us Wed, 15 Apr 2026 09:05:03 +0530 Wed, 15 Apr 2026 09:05:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=98820 Reassessment under Section 148 requires prima facie material showing a live link between the seized material and alleged income escaping assessment. The High Court held that vague, non-specific loose papers referring only to survey numbers, a rate and a third person's name, without the assessee's name or any nexus to her, could not justify reopening. The expressions "relates to" and "pertains to" in Explanation 2 to Section 148 cannot be applied in isolation; the Revenue must assess the material against surrounding circumstances and record prima facie relevancy. As the information lacked that connection, the notice and consequential reopening were quashed. Highlights Income Tax Wed, 15 Apr 2026 09:05:03 +0530 https://www.taxtmi.com/highlights?id=98820