https://www.taxtmi.com/caselaws?id=767427 HC dismissed the challenge to reassessment, holding the AO had sufficient material to form a reason to believe and lawfully reopen assessment under s.148. The court found the AO reasonably relied on the DRP's view that the subsidiary's funds were attributable to the assessee and on earlier findings affirmed by the SC that the reopening basis was adequate. The petitioner's contention that the DRP order was misconstrued was rejected because it had not been raised previously; the court declined to revisit the first-round conclusions and upheld the reassessment action. en-us Wed, 29 Jan 2025 00:00:00 +0530 Tue, 09 Sep 2025 13:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767427 HC dismissed the challenge to reassessment, holding the AO had sufficient material to form a reason to believe and lawfully reopen assessment under s.148. The court found the AO reasonably relied on the DRP's view that the subsidiary's funds were attributable to the assessee and on earlier findings affirmed by the SC that the reopening basis was adequate. The petitioner's contention that the DRP order was misconstrued was rejected because it had not been raised previously; the court declined to revisit the first-round conclusions and upheld the reassessment action. Case-Laws Income Tax Wed, 29 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767427