https://www.taxtmi.com/caselaws?id=798032 Reassessment under Sections 147 and 148 lacks jurisdiction where its recorded reasons rely solely on additions or disallowances in subsequent assessment years that binding appellate orders have overturned. Deletion of the Revenue's position on broken-period interest, premium amortisation on held-to-maturity securities, non-performing asset interest, perpetual debt instrument interest, bad debts and wage-revision provision removes the factual foundation for a reason to believe that income escaped assessment. The reopening notice and rejection of objections are therefore liable to be quashed because the basis for reassessment no longer exists. en-us Mon, 17 Aug 2026 00:00:00 +0530 Tue, 01 Sep 2026 08:26:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798032 Reassessment under Sections 147 and 148 lacks jurisdiction where its recorded reasons rely solely on additions or disallowances in subsequent assessment years that binding appellate orders have overturned. Deletion of the Revenue's position on broken-period interest, premium amortisation on held-to-maturity securities, non-performing asset interest, perpetual debt instrument interest, bad debts and wage-revision provision removes the factual foundation for a reason to believe that income escaped assessment. The reopening notice and rejection of objections are therefore liable to be quashed because the basis for reassessment no longer exists. Case-Laws Income Tax Mon, 17 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798032