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of <h1>Reassessment under s.147 invalid where reasons to believe rely solely on material already disclosed in original assessment</h1> <h3>ASST. COMMISSIONER OF INCOME TAX 4 (1) (1) & ORS. Versus INFINITY. COM FINANCIAL SECURITIES LIMITED</h3> SC dismissed the special leave petition, upholding HC's view that reassessment initiated under s.147 was invalid where the reasons to believe relied ... Reopening of assessment u/s 147 - Eligibility of reasons to believe - HC decided [2021 (12) TMI 997 - BOMBAY HIGH COURT] all material facts had been disclosed by petitioner in the course of the regular assessment proceedings and the reasons recorded for initiation of reassessment too give reference only to the details already submitted by petitioner in the course of the original assessment proceedings and nothing more. In the absence of such fresh material, the reassessment proceedings would be invalid. HELD THAT:- The special leave petition is dismissed. Supreme Court of India; Citation: TMI. Application for special leave was considered and 'Delay condoned.' No reasons are recorded in the text provided. The Court's dispositive order: 'The special leave petition is dismissed.' No respondent counsel is noted. The brief record contains only procedural disposition without elaboration of legal principles, findings on merits, or analysis of jurisdiction, locus standi, or limitations. No further orders or directions are enumerated.
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