Assessment Order Need Not address every Queries Raised during Assessment

Aroni Commercials Limited Vs DCIT (Bombay High Court)

Bombay High Court in Aroni Commercials Limited Vs DCIT addressed the legality of reopening a tax assessment under Sections 147/148 of the Income Tax Act. The court reiterated that reassessments must be based on tangible material and not mere changes in opinion. It emphasized that the Assessing Officer (AO) must establish “reason to believe” that income has escaped assessment, with reasons recorded prior to issuing a notice under Section 148. In cases of reassessments beyond four years, an additional requirem

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