https://www.taxtmi.com/caselaws?id=790985 Reopening under the Income-tax Act cannot be sustained on speculative material that fails to establish a reliable nexus with the assessee, especially where the same facts had already been found insufficient in a connected co-owner matter. The notice under Section 148 and the reassessment under Section 147 were based on a loose paper that did not reconcile with the sale deed or the agricultural status of the land at the time of sale. As the reassessment lacked jurisdictional foundation, the consequential penalty notice under Section 271DA also failed and was quashed with the reassessment proceedings. en-us Wed, 29 Apr 2026 00:00:00 +0530 Mon, 04 May 2026 07:57:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790985 Reopening under the Income-tax Act cannot be sustained on speculative material that fails to establish a reliable nexus with the assessee, especially where the same facts had already been found insufficient in a connected co-owner matter. The notice under Section 148 and the reassessment under Section 147 were based on a loose paper that did not reconcile with the sale deed or the agricultural status of the land at the time of sale. As the reassessment lacked jurisdictional foundation, the consequential penalty notice under Section 271DA also failed and was quashed with the reassessment proceedings. Case-Laws Income Tax Wed, 29 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790985