https://www.taxtmi.com/caselaws?id=800951 Reassessment jurisdiction under sections 147 and 148 requires recorded information that is specific to the assessee and the relevant assessment year. Explanation 2(i) does not permit reopening solely on generic group-search allegations without identified seized material, escaped income, or year-specific nexus. Approval under section 151 must reflect application of mind to those particulars. Further, other income may be assessed only after assessing or reassessing the income forming the recorded basis for reopening. A reassessment cannot therefore rest solely on a disallowance of delayed employees' welfare contributions unrelated to the recorded search-based allegations. en-us Fri, 18 Sep 2026 00:00:00 +0530 Wed, 14 Oct 2026 06:17:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800951 Reassessment jurisdiction under sections 147 and 148 requires recorded information that is specific to the assessee and the relevant assessment year. Explanation 2(i) does not permit reopening solely on generic group-search allegations without identified seized material, escaped income, or year-specific nexus. Approval under section 151 must reflect application of mind to those particulars. Further, other income may be assessed only after assessing or reassessing the income forming the recorded basis for reopening. A reassessment cannot therefore rest solely on a disallowance of delayed employees' welfare contributions unrelated to the recorded search-based allegations. Case-Laws Income Tax Fri, 18 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800951