https://www.taxtmi.com/caselaws?id=468305 Reassessment under section 147 requires a demonstrable live link between the material in the Assessing Officer's possession and the belief that the assessee's income has escaped assessment. On the recorded reasons, the material only suggested routing of unaccounted income through share capital and premium in group companies, while the assessee was merely an investor; the necessary nexus with any escapement by the assessee was absent, so reopening was invalid. The notice under section 148 was not invalid on jurisdictional grounds because the return and PAN records reflected the issuing officer's jurisdiction, and a mere change of address without corresponding PAN update did not displace it. en-us Wed, 19 Oct 2022 00:00:00 +0530 Tue, 28 Apr 2026 10:46:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468305 Reassessment under section 147 requires a demonstrable live link between the material in the Assessing Officer's possession and the belief that the assessee's income has escaped assessment. On the recorded reasons, the material only suggested routing of unaccounted income through share capital and premium in group companies, while the assessee was merely an investor; the necessary nexus with any escapement by the assessee was absent, so reopening was invalid. The notice under section 148 was not invalid on jurisdictional grounds because the return and PAN records reflected the issuing officer's jurisdiction, and a mere change of address without corresponding PAN update did not displace it. Case-Laws Income Tax Wed, 19 Oct 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468305