Once AO Scrutinises Identity & Creditworthiness Of Shareholders, No Reassessment Action Without 'Additional Info' About Income Escapement: Delhi HC

The Delhi High Court has provided an important clarification on the scope of reassessment proceedings. The court ruled that once an Assessing Officer (AO) has scrutinized the identity and creditworthiness of shareholders during the original assessment, a reassessment cannot be initiated on the same issue without any new or additional information about income escapement. The case involved a situation where the AO had accepted the genuineness of the share capital received by the company during the initial scrutiny. The department later tried to reopen the assessment on the same issue. The High Court held that this amounts to a "change of opinion" by the department, which is not a valid ground for reassessment. This ruling provides finality to the issues that have already been examined and accepted during the original assessment, protecting taxpayers from repeated inquiries on the same matter.