https://www.taxtmi.com/caselaws?id=791028 Reassessment under Section 148 cannot be founded on vague seized material unless it creates a prima facie live link with the assessee and indicates escapement of income. The Gujarat HC found that a loose paper entry, dated nearly two years before the land purchase, did not name the assessee, did not connect the assessee with the broker, and was unsupported by inquiry from the sellers or any independent corroboration. Expressions such as "pertains to" and "relate to" cannot operate in vacuum. On that basis, the reopening lacked the requisite material foundation and the reassessment notice was quashed. en-us Wed, 08 Apr 2026 00:00:00 +0530 Tue, 05 May 2026 09:09:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791028 Reassessment under Section 148 cannot be founded on vague seized material unless it creates a prima facie live link with the assessee and indicates escapement of income. The Gujarat HC found that a loose paper entry, dated nearly two years before the land purchase, did not name the assessee, did not connect the assessee with the broker, and was unsupported by inquiry from the sellers or any independent corroboration. Expressions such as "pertains to" and "relate to" cannot operate in vacuum. On that basis, the reopening lacked the requisite material foundation and the reassessment notice was quashed. Case-Laws Income Tax Wed, 08 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791028