https://www.taxtmi.com/caselaws?id=461223 The Delhi HC held that reassessment proceedings must be confined to items specifically mentioned in the AO's recorded reasons under Section 148(2) for forming the opinion that income escaped assessment. Following Ranbaxy Laboratories precedent, the court ruled that Explanation 3 cannot enable the AO to deviate from, supplement, or improve upon the original reasons for initiating reassessment under Sections 147/148. The validity of reassessment initiation must be independently evaluated and cannot be confused with powers available after valid reopening. The explanations only apply once reassessment is validly initiated. Decision favored the assessee against revenue. en-us Tue, 10 Sep 2024 00:00:00 +0530 Fri, 21 Mar 2025 19:21:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461223 The Delhi HC held that reassessment proceedings must be confined to items specifically mentioned in the AO's recorded reasons under Section 148(2) for forming the opinion that income escaped assessment. Following Ranbaxy Laboratories precedent, the court ruled that Explanation 3 cannot enable the AO to deviate from, supplement, or improve upon the original reasons for initiating reassessment under Sections 147/148. The validity of reassessment initiation must be independently evaluated and cannot be confused with powers available after valid reopening. The explanations only apply once reassessment is validly initiated. Decision favored the assessee against revenue. Case-Laws Income Tax Tue, 10 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461223