Reopening is invalid when there is no direct nexus between material gathered & formation of belief of income escaping assessment

Reopening is invalid when there is no direct nexus between material gathered & formation of belief of income escaping assessment

Brief of the case:

• The Hon’ble Karnataka HC in the above cited case held that there must be a direct nexus between the material coming to the notice of the Income-Tax Officer and the formation of his belief that income has escaped assessment.Therefore, when  a material gathered by the AO is such that conclusion regarding escapement  can be made only after further investigation then reopening basis such material is not permissible because in the garb of reopening detailed assessment cannot be made.
  

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