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HC held that writ petitions are disposed and directed procedural safeguards before initiation of reassessment under s.147/148A: the assessees must file their returns by 31.10.2025; within one week of filing the AO shall disclose by email the information relied upon to propose reassessment; assessees shall have two weeks to file objections by a prescribed/accessible mode; the AO shall pass a reasoned, speaking order on those objections within two further weeks and communicate it to the assessees; if reassessment is to be initiated, the first hearing date shall be fixed with at least 30 days' advance notice. The HC reaffirmed that precedential law and Article 141 mandate affording a minimal opportunity to object before reassessment is initiated.
HC held that writ petitions are disposed and directed procedural safeguards before initiation of reassessment under s.147/148A: the assessees must file their returns by 31.10.2025; within one week of filing the AO shall disclose by email the information relied upon to propose reassessment; assessees shall have two weeks to file objections by a prescribed/accessible mode; the AO shall pass a reasoned, speaking order on those objections within two further weeks and communicate it to the assessees; if reassessment is to be initiated, the first hearing date shall be fixed with at least 30 days' advance notice. The HC reaffirmed that precedential law and Article 141 mandate affording a minimal opportunity to object before reassessment is initiated.
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