Reassessment under s.147 invalid where reasons to believe rely solely on material already disclosed in original assessment SC dismissed the special leave petition, upholding HC's view that reassessment initiated under s.147 was invalid where the reasons to believe relied ...
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Reassessment under s.147 invalid where reasons to believe rely solely on material already disclosed in original assessment
SC dismissed the special leave petition, upholding HC's view that reassessment initiated under s.147 was invalid where the reasons to believe relied solely on material already disclosed during the original assessment. The court accepted that no fresh material or new facts were placed before the assessing authority and the reasons recorded merely referenced information furnished earlier by the taxpayer; accordingly, reopening the assessment lacked jurisdiction and was not permissible.
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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