Delhi HC Quashed Reassessment Notice Due to Absence of ‘Asset’ for Extended Limitation

Deepak Nagar Vs ACIT (Delhi High Court) The Delhi High Court examined the validity of a reassessment notice issued under Section 148 of the Income Tax Act, 1961 for Assessment Year 2016–17. The petitioner challenged the notice dated 31.08.2024 and subsequent proceedings, arguing that the initiation of reassessment lacked the foundational jurisdictional requirement of the existence of an “asset” exceeding ₹50 lakh, as mandated under the proviso to Section 149(1) of the Act. It was contended that the reasons recorded by the Assessing Officer did not indicate the existence or creation of ...