SC Quashed Reopening for Lack of Valid “Reason to Believe”

ITO Vs O3 Developers Private Limited (Supreme Court of India)

The dispute arose from a notice dated 31.03.2021 issued under section 148 of the Income Tax Act, 1961, seeking to reopen the assessment of a company for Assessment Year (AY) 2017–18. The assessee had originally filed its return on 31.10.2017 declaring total income of ₹58.50 lakh. Subsequently, the company underwent a change of name and was issued a new PAN in April 2019, which later became central to the jurisdictional objection raised against the reopening notice.

The Assessing Officer relied on information

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