https://www.taxtmi.com/caselaws?id=756861 The Delhi HC quashed reassessment notices under Sections 148A and 148 for AY 2019-20. The court held that an FPI's investment in Indian shares constituted a capital account transaction, not income subject to assessment. Since funds remitted were used for securities subscription without generating income, no return filing was required. The Revenue's premise that share investments constituted escaped income was fundamentally flawed. Additionally, the court found procedural violations as discrepancies in share prices were raised in the Section 148A(d) order without being mentioned in the initial Section 148A(b) notice, violating natural justice principles. The reassessment proceedings were deemed unjustified and unsustainable. en-us Fri, 09 Aug 2024 00:00:00 +0530 Sat, 10 Aug 2024 09:06:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=756861 The Delhi HC quashed reassessment notices under Sections 148A and 148 for AY 2019-20. The court held that an FPI's investment in Indian shares constituted a capital account transaction, not income subject to assessment. Since funds remitted were used for securities subscription without generating income, no return filing was required. The Revenue's premise that share investments constituted escaped income was fundamentally flawed. Additionally, the court found procedural violations as discrepancies in share prices were raised in the Section 148A(d) order without being mentioned in the initial Section 148A(b) notice, violating natural justice principles. The reassessment proceedings were deemed unjustified and unsustainable. Case-Laws Income Tax Fri, 09 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=756861