https://www.taxtmi.com/caselaws?id=798031 Reassessment jurisdiction requires material with a direct and live nexus to the alleged escapement of income. Allegations concerning persons connected with a foreign investor, without reference to the taxpayer or its investment transaction, are remote and cannot support a reason to believe that share capital or premium represented escaped income. An inference that the taxpayer routed its own funds through an unrelated foreign investor is also unsustainable on human probabilities. Employees' PF and ESIC contributions deposited by the return-filing due date remained deductible under the law prevailing when the notice was issued; a later contrary ruling cannot retrospectively establish escapement. Neither ground validly supported reopening, requiring annulment of the reassessment notice. en-us Wed, 12 Aug 2026 00:00:00 +0530 Tue, 01 Sep 2026 08:26:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798031 Reassessment jurisdiction requires material with a direct and live nexus to the alleged escapement of income. Allegations concerning persons connected with a foreign investor, without reference to the taxpayer or its investment transaction, are remote and cannot support a reason to believe that share capital or premium represented escaped income. An inference that the taxpayer routed its own funds through an unrelated foreign investor is also unsustainable on human probabilities. Employees' PF and ESIC contributions deposited by the return-filing due date remained deductible under the law prevailing when the notice was issued; a later contrary ruling cannot retrospectively establish escapement. Neither ground validly supported reopening, requiring annulment of the reassessment notice. Case-Laws Income Tax Wed, 12 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798031