No reassessment u/s 148 without new materials forming opinion hat income had escaped assessment

Genpact India Private Limited Vs ACIT (Delhi High Court)

Conclusion: The action for reassessment which was commenced pursuant to the Section 148A(b) notice dated 27 May 2022 could not be countenanced and was liable to be quashed as there were no reasons underlying the formation of opinion that income had escaped assessment. Moreover,  reassessment action infracting the First Proviso to Section 149(1) and being barred by the prescription of limitation which applied

Held: Assessee-company was engaged in the business of providing a host of bus

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