https://www.taxtmi.com/caselaws?id=791120 Reassessment under section 147 was held invalid because the recorded reasons rested on general third-party information about alleged accommodation entries without specific linkage to the assessee. The ITAT noted that the reopening material did not identify any particular transaction, entry, bank trail, or documentary nexus showing receipt of the alleged amount, and a mere reference to the assessee as a possible beneficiary was insufficient. In the absence of independent application of mind and tangible material creating a live nexus with alleged escapement of income, the statutory jurisdiction for reassessment was not satisfied, and the challenge to reopening succeeded. en-us Thu, 30 Apr 2026 00:00:00 +0530 Wed, 06 May 2026 08:32:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791120 Reassessment under section 147 was held invalid because the recorded reasons rested on general third-party information about alleged accommodation entries without specific linkage to the assessee. The ITAT noted that the reopening material did not identify any particular transaction, entry, bank trail, or documentary nexus showing receipt of the alleged amount, and a mere reference to the assessee as a possible beneficiary was insufficient. In the absence of independent application of mind and tangible material creating a live nexus with alleged escapement of income, the statutory jurisdiction for reassessment was not satisfied, and the challenge to reopening succeeded. Case-Laws Income Tax Thu, 30 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791120