https://www.taxtmi.com/caselaws?id=470571 Reassessment under Section 148 cannot be initiated solely from an inquiry commission report alleging under-invoicing of iron-ore exports. The report's comparison of export prices with those charged by other exporters was only an opinion and did not establish that the assessee realised consideration above the declared invoice value. Reopening requires the Assessing Officer's independent application of mind to tangible material showing a rational nexus, or live link, with actual income escaping assessment. The article states that the Karnataka HC quashed the reopening notice and objection-rejection order for want of jurisdiction. en-us Fri, 17 Oct 2025 00:00:00 +0530 Fri, 31 Jul 2026 10:30:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470571 Reassessment under Section 148 cannot be initiated solely from an inquiry commission report alleging under-invoicing of iron-ore exports. The report's comparison of export prices with those charged by other exporters was only an opinion and did not establish that the assessee realised consideration above the declared invoice value. Reopening requires the Assessing Officer's independent application of mind to tangible material showing a rational nexus, or live link, with actual income escaping assessment. The article states that the Karnataka HC quashed the reopening notice and objection-rejection order for want of jurisdiction. Case-Laws Income Tax Fri, 17 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470571