Summary
- The Supreme Court has upheld the Delhi High Court's ruling, dismissing the Revenue's special leave petition regarding BPTP Limited's reassessment for AY 2012-13 and AY 2013-14.
- The High Court previously quashed notices under Sections 147/148, stating there was no failure by BPTP to disclose material facts during original assessments.
- The Supreme Court's dismissal does not provide additional reasoning but leaves the High Court's judgment intact, confirming the limitations on reopening assessments.
- This decision reinforces the principle that reassessment cannot be based solely on a change of opinion without tangible evidence of income escapement.
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