Section 148 lacks allegations of non-disclosure; jurisdiction assumption U/s. 147 is invalid

Dr. Willmar Schwabe India Private Limited Vs Additional Commissioner of Income Tax & Ors. (Delhi High Court) In a landmark decision, the Delhi High Court addressed the complexities surrounding Sections 147 and 148 of the Income Tax Act, 1961, in the case of Dr. Willmar Schwabe India Pvt. Ltd. Vs Additional Commissioner of Income Tax & Ors. This case scrutinized the validity of a notice issued under Section 148 for the reassessment of income for the Assessment Year (AY) 2012-13, along with an order disposing of objections to the reassessment proceedings. Detailed Analysis The core issue...