Reassessment notice cannot rest on unverified portal information lacking assessee-specific material.

The petitioners challenged the notice issued under Section 148 of the Income-tax Act, 1961, dated 29 June 2025, and the consequential order under Section 148A(3) for Assessment Year 2019–20.

The reopening was based on information available on the Insight portal and a statement of Angadia Shri Nilesh Pranjivan Bhatia, alleging that income of ₹2,14,42,208 had escaped assessment through transactions involving the petitioner.

The petitioners contended that neither the notice nor the order disclosed any material connecting them with the alleged Angadia transaction.

On examining the notice issued under Section 148A(1) and the order under Section 148A(3), the Court found that no petitioner-specific transaction or supporting material had been disclosed, and that the Assessing Officer had not independently verified the information.

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 Angadia transaction or identify any petitioner-specific escaped income?

Whether the Assessing Officer could initiate reassessment proceedings merely on the basis of information available on the Insight portal without independently verifying and applying mind to that information?

The Court applied Sections 148, 148A(1) and 148A(3) of the Income-tax Act, 1961, which require the Assessing Officer to possess and examine information suggesting that income chargeable to tax has escaped assessment, provide the assessee an opportunity to respond, and pass a reasoned order after considering the available material.

The Court relied on the principle that reassessment proceedings cannot be initiated on the basis of vague, unverified or generic information and that the Assessing Officer must independently apply his mind rather than mechanically rely on information from the Insight portal.

The Court also relied on Vasuki Global Industrial Limited v. Principal Chief Commissioner of Income Tax, [2025] 180 taxmann.com 16 (Gujarat), which holds that information received through the Insight portal, including information originating from the DGGI, must be verified and cannot by itself justify reopening without proper application of mind.

The Court found that the notice under Section 148A(1) merely referred to an alleged transaction of ₹2,14,42,208 with the Angadia but contained no material connecting that transaction to the petitioner.

The alleged amount was identically attributed to several ceramic-industry assessees, indicating that the information had been used generically rather than being correlated with the petitioner’s individual records.

Although the petitioner’s reply was reproduced in the Section 148A(3) order, the Assessing Officer neither supplied the underlying material nor verified the genuineness and relevance of the Insight portal information.

Consequently, the Court held that the statutory requirement of application of mind was not satisfied and that the proceedings amounted to a prohibited roving and fishing inquiry based on unverified information.

It held that the reassessment action was unsustainable because the notice and order failed to disclose any petitioner-specific material demonstrating escapement of income and were based on unverified, generic information from the Insight portal.

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