Reassessment Based on Insight Portal Info Must Be Under Sections 147/148 if Section 153C Jurisdictional Conditions Are Not Met

Daisy Distributors Pvt. Ltd. Vs ITO (Delhi High Court)

Conclusion: Where jurisdictional condition for AO of assessee to assume jurisdiction under Section 153C was not satisfied, in any event AO was not precluded from initiating proceedings under Section 148A on the basis of the information available on the insight portal, which was suggestive of the fact that assessee’s income for AY 2015- 16 had escaped assessment.

Held: AO had issued a notice under Section 148(A)(b) for Assessment Year (AY) 2015- 16, inter alia, stating that

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