Held that there needs to be close nexus between the material before the AO and the belief which he has formed. Since for the assessment years under challenge, no new tangible material has been brought by the AO to justify the reopening, the notice issued under section 148 is liable to be quashed and so also, the orders consequent to such notice. (AY. 2008-09 to 2011-12)
Bentley Nevada Inc. v. DCIT (2022) 194 ITD 10 / 94 ITR 503 (Delhi)(Trib.)
S. 147 : Reassessment-Business connection-No new tangible material-Reassessment is bad in law. [S. 9(1)(i), 148]