Reassessment Notice Can't Be Based On 'General Information' From Investigation Wing Of Income Tax Dept: Delhi High Court

In a significant ruling, the Delhi High Court has held that a reassessment notice issued by the Income Tax Department cannot be based on general information received from its investigation wing. The court stated that for a reassessment to be valid, the Assessing Officer must have a specific and concrete "reason to believe" that a particular income has escaped assessment. Merely acting on a general tip-off or a non-specific report from the investigation wing, without an independent application of mind by the AO, is not sufficient. This judgment protects taxpayers from being subjected to reassessment proceedings based on vague or unsubstantiated information. It reinforces the principle that the power of reassessment must be exercised based on tangible material and not on mere suspicion or borrowed satisfaction, thereby preventing fishing and roving inquiries by the department.