Unverified Insight Portal Information Cannot Justify Reassessment Without a Verified Taxpayer-Specific Income-Escape Nexus or Demonstrated Application of Mind
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....Unverified Insight Portal information cannot justify reassessment where it does not identify any transaction linking the taxpayer to alleged escaped income. Reassessment must rest on material demonstrating a taxpayer-specific nexus and application of mind; it cannot be used for a roving and fishing inquiry. Where the underlying material is not supplied, the alleged-beneficiary chart identifies no attributable transaction, and the Assessing Officer does not verify the information's genuineness, the reassessment notice and order under section 148A(3) lack a valid foundation. The reassessment proceedings were quashed and the writ petition was allowed.....
TaxTMI