HC quashes reopening notice as reason to believe has no rational nexus to belief for escapement of income

Kurz India Private Limited Vs PCIT (Delhi High Court) Appellant submits that in this case reopening is initiated on the basis of review and re-appreciation of the same material i.e. audited accounts which were subject to verification in the course of original assessment proceedings under Section 143(3) which is not permissible in law. Upon perusal of the paper book, this Court finds that the order dated 27th December, 2021 disposing of the objections filed by the petitioner does not deal with any of the contentions or submissions advanced by the petitioner. In fact, the impugned order is based...