https://www.taxtmi.com/caselaws?id=779519 The challenge to reopening of assessment was sustained because the Revenue did not produce the recorded reasons or the original Section 143(3) assessment order needed to test the CIT and Tribunal's concurrent findings. Those findings rested on objections that included non-disclosure of reasons, no suppression, the effect of the revised return under Section 115JB, non-disposal of objections, and change of opinion. In the absence of the relevant material, the Revenue could not show perversity or any basis for appellate interference. The High Court's refusal to interfere was therefore justified, and the reassessment challenge did not succeed. en-us Fri, 19 Sep 2025 00:00:00 +0530 Tue, 10 Feb 2026 14:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779519 The challenge to reopening of assessment was sustained because the Revenue did not produce the recorded reasons or the original Section 143(3) assessment order needed to test the CIT and Tribunal's concurrent findings. Those findings rested on objections that included non-disclosure of reasons, no suppression, the effect of the revised return under Section 115JB, non-disposal of objections, and change of opinion. In the absence of the relevant material, the Revenue could not show perversity or any basis for appellate interference. The High Court's refusal to interfere was therefore justified, and the reassessment challenge did not succeed. Case-Laws Income Tax Fri, 19 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779519