Reasons disclosed to assessee for reassessment u/s. 148 cannot be improved subsequently: Delhi HC

Subhash Chander Dabas Vs ACIT (Delhi High Court) Delhi High Court held that validity of reassessment under section 148 of the Income Tax Act has to be determined based on original reasons disclosed to the assessee. Such reasons cannot be improved upon subsequently. Facts- The writ petitioner impugns the proceeding for reassessment commenced in terms of Section 148 of the Income Tax Act, 1961 and pertaining to Assessment Year 2012-13. Since the proceedings for reassessment were commenced prior to the procedure for reassessment coming to be recast by virtue of Finance Act, 2021, it was the proce...