The Assessing Officer reopened the assessment beyond three years on the basis of information available on the ITBA/INSIGHT Portal that the assessee had purchased an immovable property for ₹62.02 lakh and treated the assessee as having escaped income exceeding ₹50 lakh. The assessee explained that she was only a co-owner of the property, the purchase was jointly made with her husband, and the consideration had been paid out of her husband’s NRE funds. The Tribunal held that before issuing notice under sections 148A(b) and 148, the Assessing Officer had failed to verify the registered sale deed, which would have revealed that the assessee’s share in the property was below ₹50 lakh. Mere information available on the ITBA/INSIGHT Portal could not constitute the books of account or other evidence contemplated under section 149(1)(b). The Tribunal further held that the reopening was contrary to CBDT Circular F. No. 299/10/2022-Dir(Inv.III)/647 dated 22-08-2022, which mandates independent verification of portal information before initiating reassessment proceedings. Following Smt. Sunita Purushottam Virgincar v. ITO (2024) 164 taxmann.com 352 (Bom.) (HC)  the Tribunal held that the notice issued under section 148 after the expiry of three years suffered from a jurisdictional defect and consequently quashed the reassessment order. (ITA No. 3147/PUN/2025, dt. 21-07-2026, (AY. 2016-17)