https://www.taxtmi.com/caselaws?id=348832 Delhi HC held that reassessment under Sections 147 and 148 was invalid due to lack of failure to disclose material facts. The assessee had fully disclosed five companies' subscription to its capital during original assessment proceedings, including company names, share numbers, and amounts received. The reasons to believe contained identical information already provided by the assessee, with no new material discovered. Primary facts remained undisputed - the five companies existed, subscribed to shares, made payments, and were assessed to tax. Revenue's reliance on an investigation report not annexed to reasons was insufficient. Since no undisclosed material facts were established and this constituted a jurisdictional requirement, the assumption of jurisdiction was erroneous. The petition was decided in favor of the assessee, invalidating the reassessment proceedings. en-us Mon, 25 Sep 2017 00:00:00 +0530 Mon, 21 Jul 2025 17:09:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=348832 Delhi HC held that reassessment under Sections 147 and 148 was invalid due to lack of failure to disclose material facts. The assessee had fully disclosed five companies' subscription to its capital during original assessment proceedings, including company names, share numbers, and amounts received. The reasons to believe contained identical information already provided by the assessee, with no new material discovered. Primary facts remained undisputed - the five companies existed, subscribed to shares, made payments, and were assessed to tax. Revenue's reliance on an investigation report not annexed to reasons was insufficient. Since no undisclosed material facts were established and this constituted a jurisdictional requirement, the assumption of jurisdiction was erroneous. The petition was decided in favor of the assessee, invalidating the reassessment proceedings. Case-Laws Income Tax Mon, 25 Sep 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=348832