Reopening assessment requires substantiating material, not mere allegations.

The High Court ruled that reopening an assessment requires substantiated material, not just allegations. The Assessing Officer (AO) issued a notice to the petitioner, alleging receipt of accommodation entries from entities controlled by a third party. The petitioner denied these claims and provided bank account details. The court determined that the AO cannot reopen the assessment without examining evidence to prove the petitioner received such entries. Mere allegations are insufficient, and the AO must verify basic facts before proceeding. Consequently, the notices and order issued under sections 148, 148A(b), and 148A(d) were set aside. .....

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