https://www.taxtmi.com/caselaws?id=792356 Reassessment under sections 147 and 148 was invalid because the recorded reasons relied mainly on Insight Portal and Investigation Wing information without disclosing adequate material linkage, transaction particulars, or a live link to form an independent reason to believe that income had escaped assessment. The tribunal treated the reopening as based on borrowed satisfaction and found insufficient application of mind in the formation of belief. As the foundation for reopening was unsustainable, the reassessment proceedings and consequent reassessment order were quashed; the merits of the disallowances were not examined. en-us Fri, 22 May 2026 00:00:00 +0530 Wed, 27 May 2026 07:29:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792356 Reassessment under sections 147 and 148 was invalid because the recorded reasons relied mainly on Insight Portal and Investigation Wing information without disclosing adequate material linkage, transaction particulars, or a live link to form an independent reason to believe that income had escaped assessment. The tribunal treated the reopening as based on borrowed satisfaction and found insufficient application of mind in the formation of belief. As the foundation for reopening was unsustainable, the reassessment proceedings and consequent reassessment order were quashed; the merits of the disallowances were not examined. Case-Laws Income Tax Fri, 22 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792356