https://www.taxtmi.com/caselaws?id=790492 Reopening of assessment must rest on the foundational material and the reasons initially recorded; the final order under section 148A(d) cannot shift to a new basis unrelated to the original allegation. Here, the notice was founded on alleged fictitious losses in equity and derivative trading, but the final opinion instead relied on alleged sham dividend transactions and colourable devices. That change in the basis of reassessment was treated as impermissible alteration of reasons, and the Supreme Court declined to interfere with the Delhi High Court's decision. en-us Mon, 20 Apr 2026 00:00:00 +0530 Sat, 25 Apr 2026 11:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790492 Reopening of assessment must rest on the foundational material and the reasons initially recorded; the final order under section 148A(d) cannot shift to a new basis unrelated to the original allegation. Here, the notice was founded on alleged fictitious losses in equity and derivative trading, but the final opinion instead relied on alleged sham dividend transactions and colourable devices. That change in the basis of reassessment was treated as impermissible alteration of reasons, and the Supreme Court declined to interfere with the Delhi High Court's decision. Case-Laws Income Tax Mon, 20 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790492