https://www.taxtmi.com/caselaws?id=794501 Reassessment under section 148 requires a live nexus between tangible material and the Assessing Officer's independent reason to believe that income has escaped assessment; reopening based only on Investigation Wing information, without corroboration, verification, or quantified escapement, is treated as borrowed satisfaction and invalid. On the section 143(2) issue, the Tribunal stated that the notice requirement arises only when a return is filed in response to the section 148 notice, so no separate defect arose where no return was filed. The reassessment notice and order were quashed, and the additions did not survive. en-us Thu, 09 Apr 2026 00:00:00 +0530 Tue, 07 Jul 2026 08:39:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794501 Reassessment under section 148 requires a live nexus between tangible material and the Assessing Officer's independent reason to believe that income has escaped assessment; reopening based only on Investigation Wing information, without corroboration, verification, or quantified escapement, is treated as borrowed satisfaction and invalid. On the section 143(2) issue, the Tribunal stated that the notice requirement arises only when a return is filed in response to the section 148 notice, so no separate defect arose where no return was filed. The reassessment notice and order were quashed, and the additions did not survive. Case-Laws Income Tax Thu, 09 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794501