Section 148 Notice Based on ‘Factually Erroneous’ Transaction Year Invalid: Delhi HC

Fosun Pharma Industrial Pte. Ltd. Vs ACIT/DCIT (Delhi High Court)

Delhi HC Quashes Reassessment Against Fosun Pharma; Terms AO’s Basis “Factually Erroneous”, Remands Matter for Fresh Consideration

The Petitioner had challenged the show-cause notice dt 30.03.2025 issued u/s 148A(1), the order dt 28.06.2025 passed u/s 148A(3), & the consequent reassessment notice dated 28.06.2025 issued u/s 148. The primary allegation in the show-cause notice was that a sum of ₹43,24,65,18,408/- had been received by the Petitioner during AY 2019-20. The Petitioner,

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