https://www.taxtmi.com/caselaws?id=770520 The HC dismissed the appeal challenging reassessment proceedings under Section 148A. The assessee argued that the AO sought to reopen assessment on the same grounds as previous proceedings. However, the court found that the notice under Section 148A(b) was based on completely different reasons - information received from search and seizure operations against a third party, alleging the assessee was a beneficiary of accommodation transactions. The court held that these new grounds had no bearing on any pending or disposed proceedings, making the department's action jurisdictionally valid. The court distinguished cited precedents as factually inapplicable and found no grounds for interference under Article 226. en-us Mon, 05 May 2025 00:00:00 +0530 Sat, 10 May 2025 11:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=770520 The HC dismissed the appeal challenging reassessment proceedings under Section 148A. The assessee argued that the AO sought to reopen assessment on the same grounds as previous proceedings. However, the court found that the notice under Section 148A(b) was based on completely different reasons - information received from search and seizure operations against a third party, alleging the assessee was a beneficiary of accommodation transactions. The court held that these new grounds had no bearing on any pending or disposed proceedings, making the department's action jurisdictionally valid. The court distinguished cited precedents as factually inapplicable and found no grounds for interference under Article 226. Case-Laws Income Tax Mon, 05 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=770520