https://www.taxtmi.com/caselaws?id=767490 The Delhi HC allowed the appeal and quashed the ITAT judgment regarding reopening of assessment under section 147. The ITAT incorrectly applied criminal law principles requiring proof "beyond reasonable doubt" to tax law provisions concerning "reason to believe" under section 148. The HC held that in taxing statutes, "reason to believe" must be based on objective materials and reasonable view, not criminal law standards. The court relied on SC precedents establishing that tangible material justifying scrutiny of returns is sufficient for valid reopening, distinguishing tax provisions from penal statutes requiring higher burden of proof. en-us Mon, 10 Mar 2025 00:00:00 +0530 Wed, 19 Mar 2025 06:45:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767490 The Delhi HC allowed the appeal and quashed the ITAT judgment regarding reopening of assessment under section 147. The ITAT incorrectly applied criminal law principles requiring proof "beyond reasonable doubt" to tax law provisions concerning "reason to believe" under section 148. The HC held that in taxing statutes, "reason to believe" must be based on objective materials and reasonable view, not criminal law standards. The court relied on SC precedents establishing that tangible material justifying scrutiny of returns is sufficient for valid reopening, distinguishing tax provisions from penal statutes requiring higher burden of proof. Case-Laws Income Tax Mon, 10 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767490