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. A commission report is an opinion, not definitive proof that export consideration exceeded declared invoice values. Reopening requires the Assessing Officer's independent application of mind to tangible material establishing a rational connection or live link between the alleged price difference and income escaping assessment. Without such independent material or factual verification, the reassessment notice and rejection of objections lack jurisdiction and are liable to be quashed. 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. A commission report is an opinion, not definitive proof that export consideration exceeded declared invoice values. Reopening requires the Assessing Officer's independent application of mind to tangible material establishing a rational connection or live link between the alleged price difference and income escaping assessment. Without such independent material or factual verification, the reassessment notice and rejection of objections lack jurisdiction and are liable to be quashed. Case-Laws Income Tax Fri, 17 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470571