2026 (3) TMI 1505 - SCH - Income Tax

Natural justice in reassessment notices: absence of notice on alleged non-existent entity sustained the High Court's view.

Reassessment proceedings under section 148A were challenged where the notice was based on High Risk CRIU/VRU information from the Insight Portal and ... Validity of reassessment proceedings - notice as issued u/s 148A(b) to the petitioner on the basis of High Risk CRIU/VRU information available on ‘Insight Portal’ - denial of principle of natural justice - allegation of entity being a non-existent bogus entity - receipt of accommodation entries in the form of bogus capital expenses from fictitious entity - HC [2025 (2) TMI 775 - DELHI HIGH COURT] held without issuing any notice in respect of the alleged non-existence of the said entity at the Jasola address and calling for an explanation in that regard, the respondent/Revenue passed the impugned order u/s 148A (d) of the Act dated 31.08.2024. This procedure, to our mind, is abject violation and infraction of the principles of natural justice, inasmuch as, the conclusion regarding the said entity being a non-existent bogus entity was never put to the petitioner in the show cause notice HELD THAT:- No ground to interfere with the impugned judgment in exercise of our jurisdiction under Article 136 of the Constitution of India. Accordingly, the special leave petition is dismissed. Outcome: Special Leave Petition dismissed.