https://www.taxtmi.com/caselaws?id=468272 Reassessment under Sections 148A(b), 148A(d) and 148 must rest on the original reasons and foundational material available at initiation; those reasons cannot be substituted by a later, different basis in the final order. Here, the notice alleged fictitious trading losses, but the final order shifted to sham dividend transactions, making the reassessment unsustainable. The Court also reiterated that reopening requires tangible information with a live link to a belief that income has escaped assessment, and the Assessing Officer cannot cure an initial absence of material by adding new allegations later. The writ petition succeeded and the reassessment proceedings were quashed, with liberty to proceed afresh in accordance with law. en-us Wed, 05 Mar 2025 00:00:00 +0530 Fri, 24 Apr 2026 19:49:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468272 Reassessment under Sections 148A(b), 148A(d) and 148 must rest on the original reasons and foundational material available at initiation; those reasons cannot be substituted by a later, different basis in the final order. Here, the notice alleged fictitious trading losses, but the final order shifted to sham dividend transactions, making the reassessment unsustainable. The Court also reiterated that reopening requires tangible information with a live link to a belief that income has escaped assessment, and the Assessing Officer cannot cure an initial absence of material by adding new allegations later. The writ petition succeeded and the reassessment proceedings were quashed, with liberty to proceed afresh in accordance with law. Case-Laws Income Tax Wed, 05 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468272