https://www.taxtmi.com/caselaws?id=791937 Reassessment under sections 147 and 148 cannot be sustained where the Assessing Officer acts only on Investigation Wing information and suspicion without independent application of mind or tangible material; the reopening was therefore invalid. A scrutiny assessment under section 143(3) read with section 147 also fails where no notice under section 143(2) is issued for the relevant assessment year, because that notice is mandatory and the defect is not cured by participation. On these principles, the reassessment proceedings and resulting assessment order were quashed. en-us Fri, 15 May 2026 00:00:00 +0530 Wed, 20 May 2026 08:31:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791937 Reassessment under sections 147 and 148 cannot be sustained where the Assessing Officer acts only on Investigation Wing information and suspicion without independent application of mind or tangible material; the reopening was therefore invalid. A scrutiny assessment under section 143(3) read with section 147 also fails where no notice under section 143(2) is issued for the relevant assessment year, because that notice is mandatory and the defect is not cured by participation. On these principles, the reassessment proceedings and resulting assessment order were quashed. Case-Laws Income Tax Fri, 15 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791937