https://www.taxtmi.com/caselaws?id=756221 Delhi HC held that reassessment proceedings under Section 147 must be based on original reasons recorded in Section 148(2) notice. The assessing officer cannot change stance or introduce fresh reasoning in subsequent orders. The court emphasized that validity of reassessment depends on whether original reasons were tenable and sufficient. Following precedents in Ranbaxy Laboratories and other cases, the court ruled that Explanation 3 does not permit deviation from or supplementation of original reasons. The connection between Section 148A(b) notice and Section 148A(d) order remains indelible, and any attempt to alter the foundational reasoning invalidates the proceedings. Writ petitions were allowed, quashing the impugned notices and orders. en-us Thu, 18 Jul 2024 00:00:00 +0530 Mon, 29 Jul 2024 10:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=756221 Delhi HC held that reassessment proceedings under Section 147 must be based on original reasons recorded in Section 148(2) notice. The assessing officer cannot change stance or introduce fresh reasoning in subsequent orders. The court emphasized that validity of reassessment depends on whether original reasons were tenable and sufficient. Following precedents in Ranbaxy Laboratories and other cases, the court ruled that Explanation 3 does not permit deviation from or supplementation of original reasons. The connection between Section 148A(b) notice and Section 148A(d) order remains indelible, and any attempt to alter the foundational reasoning invalidates the proceedings. Writ petitions were allowed, quashing the impugned notices and orders. Case-Laws Income Tax Thu, 18 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=756221