https://www.taxtmi.com/caselaws?id=451238 HC upheld reassessment notice under section 147, finding the AO had bona fide reasons based on an email report from the Ahmedabad Investigation Directorate analyzing NSE data and alleging misuse of Client Code Modification for tax evasion. The court held that the reasons communicated to the assessee matched the record in substance; minor linguistic discrepancies did not vitiate the reassessment. The HC refused to allow interference, emphasizing that while reasons given must align with the record, insignificant variations in wording are not a ground to quash reassessment. Decision against the assessee. en-us Wed, 20 Mar 2024 00:00:00 +0530 Mon, 01 Sep 2025 10:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=451238 HC upheld reassessment notice under section 147, finding the AO had bona fide reasons based on an email report from the Ahmedabad Investigation Directorate analyzing NSE data and alleging misuse of Client Code Modification for tax evasion. The court held that the reasons communicated to the assessee matched the record in substance; minor linguistic discrepancies did not vitiate the reassessment. The HC refused to allow interference, emphasizing that while reasons given must align with the record, insignificant variations in wording are not a ground to quash reassessment. Decision against the assessee. Case-Laws Income Tax Wed, 20 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=451238