Reopening invalid – Failure to supply material u/s 148A(b) violates natural justice; assessment quashed – ITAT Mumbai

Gedalia Multitrading Pvt. Ltd. Vs NFAC/ITO (ITAT Mumbai) In Gedalia Multitrading Pvt. Ltd. vs ITO (A.Y. 2018-19), the assessee challenged reopening under the new regime on the ground that the notice u/s 148A(b) was issued without furnishing enquiry reports and supporting material, thereby preventing effective reply. The Tribunal noted that only reasons recorded were shared, while underlying material forming basis of reopening was not supplied. The ITAT held that under the amended reassessment framework, all material relied upon must be provided to the assessee to enable meaningful response, as...