The High Court considered the validity of reassessment orders ...

High Court ruled that reasons for reassessment orders must match notice reasons. Appellants must raise objections within 6 weeks.

Case Laws     Income Tax

June 17, 2024

The High Court considered the validity of reassessment orders u/s 148A(d) where reasons differed from those in notices u/s 148A(b). The primary issue was the taxability of buyout amount and interest on fixed deposit. The Court held that notices u/s 148A(b) must contain reasons for the assessee to respond effectively. Failure to disclose reasons renders the notice ineffective. The Court noted the importance of Section 148A enquiry before issuing notice u/s 148. Orders u/s 148A(d) were deemed as notices u/s 148A(b), requiring appellants to submit objections within six weeks. Any objections would be considered, and orders passed within six weeks after a hearing.

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