There Cannot Be 'Disconnect' Between Reasons For Initiating Reassessment U/S 147 Of IT Act & Grounds On Which Final Order Is Passed: Delhi HC

The Delhi High Court ruled that there cannot be a disconnect between the reasons for initiating reassessment under Section 147 of the Income Tax Act and the grounds on which the final order is passed. The Court held that if the grounds for reassessment are based on incorrect or irrelevant reasons, the final order could be deemed invalid. This decision ensures that the reassessment process is transparent and rooted in valid grounds, protecting taxpayers from arbitrary actions. It underscores the necessity for consistency between the reassessment notice and the final assessment order.