https://www.taxtmi.com/caselaws?id=469165 Reassessment under sections 147 and 148 requires tangible material with a direct nexus to alleged escapement of income for the relevant year. Material drawn from an Investigation Wing excel sheet and third-party statements, without independent verification, was treated as borrowed and insufficient for forming the requisite belief. Where such material is used against the assessee, the underlying seized documents must be disclosed and a fair opportunity, including cross-examination of relied-upon persons, should be provided. In the stated analysis, the absence of a legally sustainable basis for reopening meant the reassessment and consequential addition could not stand. en-us Fri, 29 Aug 2025 00:00:00 +0530 Fri, 05 Jun 2026 19:01:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469165 Reassessment under sections 147 and 148 requires tangible material with a direct nexus to alleged escapement of income for the relevant year. Material drawn from an Investigation Wing excel sheet and third-party statements, without independent verification, was treated as borrowed and insufficient for forming the requisite belief. Where such material is used against the assessee, the underlying seized documents must be disclosed and a fair opportunity, including cross-examination of relied-upon persons, should be provided. In the stated analysis, the absence of a legally sustainable basis for reopening meant the reassessment and consequential addition could not stand. Case-Laws Income Tax Fri, 29 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469165