Reassessment cannot rest on unverified Insight Portal information lacking assessee-specific material.

The petitioner, a ceramics-business assessee, challenged the notice issued under Section 148 of the Income-tax Act, 1961, and the corresponding order under Section 148A(3) for Assessment Year 2019–20.

The proposed reopening alleged escapement of income of ₹2,14,42,208 based on information available on the Insight portal and an alleged transaction involving Angadiya Shri Nilesh Pranjivan Bhatia.

The petitioner contended that the notice and order contained no material connecting it with the alleged transaction and that several similarly situated ceramic dealers had received notices mentioning the identical amount.

The Assessing Officer allegedly failed to furnish the underlying material or independently verify the portal information.

The Revenue maintained that the Insight portal information and the statement of the Angadiya disclosed distribution of the amount among various assessees, justifying initiation of reassessment proceedings.

Whether the notice under Section 148 and the order under Section 148A(3) were valid when they did not disclose material linking the petitioner to the alleged transaction or specify the petitioner-wise amount of escaped income.

Whether the Assessing Officer could rely on information from the Insight portal and the Angadiya’s statement without supplying the underlying material to the petitioner and without independently verifying the information.

Whether the writ petition should be rejected on the ground that the petitioner had an alternative remedy of participating in the reassessment proceedings.

The Court applied Sections 148 and 148A(1) and (3) of the Income-tax Act, 1961, which require the Assessing Officer to possess and disclose relevant material indicating escapement of income, consider the assessee’s response, and pass a reasoned order before issuing a notice under Section 148.

It relied on Vasuki Global Industrial Limited v. Principal Chief Commissioner of Income Tax, [2025] 180 taxmann.com 16 (Gujarat), for the principle that the Assessing Officer must apply an independent mind and verify information obtained from the Insight portal rather than mechanically rely upon it.

The Court further applied the settled rule that reassessment proceedings cannot be initiated merely for a roving or fishing inquiry on the basis of unverified information.

The Court found that neither the notice nor the order identified any transaction between the petitioner and the Angadiya or specified how the alleged amount of ₹2,14,42,208 was attributable to the petitioner.

Although the order referred to a chart of alleged beneficiaries, the petitioner-wise amount was absent, and the underlying material was not supplied.

The identical amount mentioned in notices issued to several ceramic dealers, coupled with the absence of a petitioner-specific correlation, indicated that the Assessing Officer had proceeded mechanically.

The Assessing Officer also failed to verify the genuineness and relevance of the Insight portal information or demonstrate independent application of mind.

Consequently, the statutory preconditions for valid assumption of reassessment jurisdiction were not satisfied.

It held that the impugned proceedings were based on unverified and non-specific information, without material linking the petitioner to the alleged transaction or demonstrating application of mind.

The writ petition was accordingly allowed, and the notice dated 29 June 2025 issued under Section 148 and the order dated 29 June 2025 passed under Section 148A(3) of the Income-tax Act were quashed and set aside.