https://www.taxtmi.com/caselaws?id=796522 Reassessment after processing under Section 143(1) still requires recorded reasons based on tangible, relevant material establishing a rational live link to income escaping assessment. Although no prior opinion is formed through such processing, the absence of change of opinion does not remove this jurisdictional condition. Treating client funds received by a regulated stock-broker as its income merely because they exceeded reported turnover, without material showing conversion into proprietary income, reflects suspicion and an erroneous understanding of the transactions. The reassessment notice and consequential reassessment were therefore invalid for lack of jurisdiction. en-us Fri, 31 Jul 2026 00:00:00 +0530 Thu, 06 Aug 2026 09:11:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796522 Reassessment after processing under Section 143(1) still requires recorded reasons based on tangible, relevant material establishing a rational live link to income escaping assessment. Although no prior opinion is formed through such processing, the absence of change of opinion does not remove this jurisdictional condition. Treating client funds received by a regulated stock-broker as its income merely because they exceeded reported turnover, without material showing conversion into proprietary income, reflects suspicion and an erroneous understanding of the transactions. The reassessment notice and consequential reassessment were therefore invalid for lack of jurisdiction. Case-Laws Income Tax Fri, 31 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796522