https://www.taxtmi.com/caselaws?id=470650 Reassessment jurisdiction is examined against mandatory procedural safeguards: timely service of notice under section 143(2), furnishing of recorded reopening reasons, and separate speaking disposal of objections. The notes state that absent proof of service, supply of recorded reasons, or disposal of objections, reassessment cannot be sustained. They also address section 151 sanction, explaining that standardised approvals for multiple assessees and reliance on unverified Investigation Wing information may indicate mechanical or borrowed satisfaction rather than independent application of mind. On these stated principles, the reopening notice, reassessment proceedings, and consequential assessment are described as unsustainable, leaving merits additions academic. en-us Tue, 25 Mar 2025 00:00:00 +0530 Mon, 03 Aug 2026 19:04:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470650 Reassessment jurisdiction is examined against mandatory procedural safeguards: timely service of notice under section 143(2), furnishing of recorded reopening reasons, and separate speaking disposal of objections. The notes state that absent proof of service, supply of recorded reasons, or disposal of objections, reassessment cannot be sustained. They also address section 151 sanction, explaining that standardised approvals for multiple assessees and reliance on unverified Investigation Wing information may indicate mechanical or borrowed satisfaction rather than independent application of mind. On these stated principles, the reopening notice, reassessment proceedings, and consequential assessment are described as unsustainable, leaving merits additions academic. Case-Laws Income Tax Tue, 25 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470650