https://www.taxtmi.com/caselaws?id=799674 Reassessment under Sections 148A(b) and 148A(d) requires consistency between the foundational allegation in the notice and the reasons supporting the determination that income escaped assessment. Where the notice alleged that a land purchase was unrecorded, but the subsequent determination accepted disclosure of the property and instead questioned the source of funds received from a holding company, the reassessment rested on an impermissible new ground. This divergence created a jurisdictional defect, rendering the reassessment invalid and liable to be quashed. en-us Wed, 16 Sep 2026 00:00:00 +0530 Fri, 25 Sep 2026 08:16:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799674 Reassessment under Sections 148A(b) and 148A(d) requires consistency between the foundational allegation in the notice and the reasons supporting the determination that income escaped assessment. Where the notice alleged that a land purchase was unrecorded, but the subsequent determination accepted disclosure of the property and instead questioned the source of funds received from a holding company, the reassessment rested on an impermissible new ground. This divergence created a jurisdictional defect, rendering the reassessment invalid and liable to be quashed. Case-Laws Income Tax Wed, 16 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799674