https://www.taxtmi.com/caselaws?id=791931 Reassessment under section 147 was held unsustainable where the recorded reasons were based on incorrect facts, including wrong return particulars, assessment year, and alleged bank transactions, and the sanction under section 151 was not duly signed. The analysis emphasised that reopening requires reason to believe founded on tangible, live material and independent application of mind to the assessee's material; a mere suspicion or possibility of escapement is insufficient. On that basis, reassessment proceedings were treated as without jurisdiction and quashed. en-us Mon, 04 May 2026 00:00:00 +0530 Wed, 20 May 2026 08:31:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791931 Reassessment under section 147 was held unsustainable where the recorded reasons were based on incorrect facts, including wrong return particulars, assessment year, and alleged bank transactions, and the sanction under section 151 was not duly signed. The analysis emphasised that reopening requires reason to believe founded on tangible, live material and independent application of mind to the assessee's material; a mere suspicion or possibility of escapement is insufficient. On that basis, reassessment proceedings were treated as without jurisdiction and quashed. Case-Laws Income Tax Mon, 04 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791931