https://www.taxtmi.com/caselaws?id=472587 Reassessment under sections 147 and 148 requires tangible material with a live link to income escaping assessment in the relevant year. Findings from subsequent assessment years cannot be mechanically applied where the relevant year lacked global-deal agreements, related revenue transfers, and the Hyderabad unit. Material discovered during an ongoing assessment for a later year was distinguishable. Recorded reasons founded on later-year facts amounted to a reason to suspect rather than a reason to believe; the reassessment and consequential assessment were invalidated. en-us Mon, 12 Aug 2024 00:00:00 +0530 Sat, 17 Oct 2026 10:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=472587 Reassessment under sections 147 and 148 requires tangible material with a live link to income escaping assessment in the relevant year. Findings from subsequent assessment years cannot be mechanically applied where the relevant year lacked global-deal agreements, related revenue transfers, and the Hyderabad unit. Material discovered during an ongoing assessment for a later year was distinguishable. Recorded reasons founded on later-year facts amounted to a reason to suspect rather than a reason to believe; the reassessment and consequential assessment were invalidated. Case-Laws Income Tax Mon, 12 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=472587