Reopening u/s. 148 without tangible material is unsustainable in law: Gujarat HC

Narsimha Trading Co. Vs ITO (Gujarat High Court)

Gujarat High Court held that reopening of assessment under section 148 of the Income Tax Act in absence of any tangible material to arrive at primafacie reason to believe that income has escaped assessment is unsustainable in law and hence liable to be quashed.

Facts- By this petition under Article 226 of the Constitution of India, the petitioner has challenged the assumption of the jurisdiction by the respondent-Assessing Officer to issue notice dated 30.03.2021 for reopening assessment for the Assessment Yea

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