Mechanical Reliance on Suspicious Transaction Report: Gujarat HC Quashes Section 148 Reassessment Notice

Vivaansh Edutech Pvt. Ltd. Vs ACIT (Gujarat High Court) The writ petition before the Gujarat High Court challenged the legality of a notice issued under Section 148 of the Income-tax Act, 1961, and the consequential order passed under Section 148A(3), both dated 19 June 2025, seeking to reopen the petitioner’s assessment for Assessment Year 2021–22. The petitioner contended that the reopening was without jurisdiction, contrary to the amended statutory scheme, and unsupported by any material demonstrating escapement of income. The petitioner, a company incorporated under the Companies Act, ...