10-Year Reassessment Period Unjustified as Conditions Under Section 153A(1) Not Met

Smart Chip Private Limited Vs ACIT (Delhi High Court) Delhi High Court held that extended period of ten years for reassessment cannot be sustained since revenue failed to establish that expenses had resulted in the acquisition of any asset and hence conditions stipulated in the fourth proviso to Section 153A(1) of the Income Tax Act would remain unsatisfied. Facts- The petitioner has filed the present petition, inter alia, impugning a notice dated 21.03.2024 issued u/s. 148 of the Income Tax Act, 1961 and the reassessment proceedings conducted pursuant to the impugned notice. It is the petitio...