https://www.taxtmi.com/caselaws?id=796895 Identity-theft objections to transaction information linked to a PAN do not, without conclusive enquiry, prevent reassessment proceedings under the amended framework. At the Section 148-A stage, the relevant question is whether the matter is fit for a Section 148 notice, and substantial transaction information is relevant material. A GST communication that does not conclusively determine identity theft cannot establish that the taxpayer did not undertake the transactions. The defence requires evidence and examination during reassessment. Once the taxpayer substantiates non-involvement, the Revenue must produce primary positive evidence that the taxpayer undertook the disputed transactions; disputed information alone does not shift that burden. en-us Thu, 06 Aug 2026 00:00:00 +0530 Wed, 12 Aug 2026 08:20:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796895 Identity-theft objections to transaction information linked to a PAN do not, without conclusive enquiry, prevent reassessment proceedings under the amended framework. At the Section 148-A stage, the relevant question is whether the matter is fit for a Section 148 notice, and substantial transaction information is relevant material. A GST communication that does not conclusively determine identity theft cannot establish that the taxpayer did not undertake the transactions. The defence requires evidence and examination during reassessment. Once the taxpayer substantiates non-involvement, the Revenue must produce primary positive evidence that the taxpayer undertook the disputed transactions; disputed information alone does not shift that burden. Case-Laws Income Tax Thu, 06 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796895