Reassessment cannot rest on seized broker records lacking a live nexus to the assessee’s transaction.

The petitioner challenged a notice dated 18 March 2026 under Section 148 of the Income-tax Act, 1961, seeking to reopen the assessment for A.Y. 2022–23.

The reassessment was based on an entry dated 16 January 2020 in an inquiry register seized during a search of City Estate Management India.

The Revenue relied on the entry’s reference to land at Bhadaj, including Survey No. 509/A, to allege that the petitioner had paid unaccounted consideration when purchasing land with co-purchasers under a registered sale deed dated 1 June 2021.

The parties submitted that the petition could be disposed of in accordance with the High Court’s common judgment dated 8 October 2026 in *Special Civil Application No. 13210 of 2026 and allied matters*.

Whether the seized inquiry-register entry supplied a sufficient link between the petitioner and the alleged on-money payment to support reopening under Section 148 of the Act.

Whether the notice under Section 148 for A.Y. 2022–23 should be quashed in light of the Court’s findings in the common judgment dated 8 October 2026.

Section 148 of the Income-tax Act permits reassessment where the statutory conditions for reopening are met; where the Revenue relies on material seized from another person, the information must have a sufficient connection with the assessee to suggest escapement of income.

The Court considered Explanation 2(iv) to Section 148, concerning seized documents that “pertain to” or information that “relates to” an assessee, and Sections 132(4A) and 292C, which provide presumptions concerning seized material.

Applying its prior decisions, including *Naliniben Jagdishkumar Gandhi*, *Trupti Aakash Desai*, and *Kantilal Parsotamdas Patel*, the Court required a live nexus between the seized material and the assessee before reopening could be sustained.

The common judgment found that the register entry preceded the petitioner’s purchase by about one and a half years and was described by the broker as recording land or plots available for sale, not completed transactions.

The entry covered several survey numbers and a total area substantially larger than the single parcel purchased by the petitioner and co-purchasers; it also contained names not shown to be connected to the petitioner or the sale.

The broker’s statements did not identify the petitioner or the co-purchasers as parties to the transaction, and the Court found no direct or indirect link between them and the seized entry.

The present petition was disposed of on that basis, in terms of the common judgment.