SC upholds reopening of assessment under Section 147 using data from Section 148A(b) notice and insight portal risk flag

The SC dismissed the Special Leave Petitions challenging the reopening of assessment under Section 147 of the IT Act. The Court held that the information provided under Section 148A(b) notice, including data from the insight portal flagging the petitioner's case as high risk, falls within the scope of Explanation 1(i) of Section 148. Since the assessment order dated 26.03.2024 has already been passed and an appeal against it is pending before the Appellate Authority, the SC found no reason to interfere with the impugned orders.

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Citation: 2025 (4) TMI 616 - Supreme Court (Order) Summary: An assessment order dated 26.03.2024 has already been passed. The petitioner informed the Court that an appeal against that assessment order is pending consideration before the Appellate Authority. Given the pendency of the appellate remedy, the Court found "no reason for us to interfere with the order(s) impugned" and accordingly declared that "The Special Leave Petitions are dismissed." All pending applications were directed to stand disposed of. The decision rests on the principle that when an effective statutory appellate remedy is available and being pursued, interference by this Court is unwarranted; hence the SLPs were refused relief without addressing merits of the underlying assessment order.

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