Initiation of re-assessment based on material already on record is bad-in-law

IDFC Limited Vs DCIT (Madras High Court) Madras High Court held that initiation of proceedings for reassessment under section 147 of the Income Tax Act based on material already on record and without new/ tangible information is bad-in-law and liable to be quashed. Facts- The petitioner in these writ petitions is a Bank and an assessee on the file of the respondents under the provisions of the Income-Tax Act, 1961. The challenge relates to proceedings for re-assessment for assessment years 2014 – 2015 and 2017 – 2018. Notably, the facts in relation to AY 2014 – 2015 are that an original ...