Issues already examined in revision proceedings cannot be re-agitated in reassessment

Dilip Gangaram Patil Vs ACIT (Bombay High Court) Bombay High Court in Dilip Gangaram Patil vs. Assistant Commissioner of Income Tax (ACIT) ruled on the validity of reassessment proceedings initiated under Section 148 of the Income Tax Act, 1961. The petitioner, a real estate developer, challenged the notice for reassessment, asserting that the grounds for reopening the case were already examined in prior proceedings under Section 263. The court emphasized that reassessment cannot be based on issues already scrutinized unless new material facts emerge. The case stemmed from discrepancies in the...