https://www.taxtmi.com/caselaws?id=789900 Reassessment under sections 147 and 148 is vulnerable where the original scrutiny assessment under section 143(3) had already examined the share capital issue and the reopening rests only on Investigation Wing information. If the recorded reasons do not show independent inquiry, fresh tangible material, or a live nexus between the material and escapement of income, the reopening is treated as borrowed satisfaction and a mere change of opinion. On that basis, the reassessment cannot be sustained and the reopening is invalid. en-us Wed, 08 Apr 2026 00:00:00 +0530 Thu, 16 Apr 2026 08:34:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789900 Reassessment under sections 147 and 148 is vulnerable where the original scrutiny assessment under section 143(3) had already examined the share capital issue and the reopening rests only on Investigation Wing information. If the recorded reasons do not show independent inquiry, fresh tangible material, or a live nexus between the material and escapement of income, the reopening is treated as borrowed satisfaction and a mere change of opinion. On that basis, the reassessment cannot be sustained and the reopening is invalid. Case-Laws Income Tax Wed, 08 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789900