Generic Client Code Modification Allegations Insufficient for Reopening: Delhi HC

PCIT Vs Atul Goel (Delhi High Court) The present appeal was filed by the Revenue under Section 260A of the Income-tax Act, 1961 against an order dated 10.05.2025 passed by the Income Tax Appellate Tribunal, Delhi Bench “A”. The appeal arose from reassessment proceedings initiated against the assessee based on information allegedly received from the Serious Fraud Investigation Office (SFIO) regarding Client Code Modification (CCM) transactions. The Assessing Officer recorded reasons stating that, pursuant to an SFIO investigation, the assessee was a beneficiary of CCM and had earned income ...