Reassessment unsustained as based on entirely new reason which deprives assessee’s right to object: Delhi HC

Banyan Real Estate Fund Mauritius Vs ACIT Circle International Tax & Anr. (Delhi High Court)

Delhi High Court held that initiation of reassessment based on entirely new or previously undisclosed material or reasoning deprives assessee’s right to effectively object the proposed reassessment action. Accordingly, the impugned action is rendered wholly unsustainable.

Facts- The writ petitioner impugns the validity of the reassessment action which has come to be initiated pursuant to the notice dated 27 April 2023 under Section 148 of the Income Tax Act, 19

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