Summary
- The Sikkim High Court quashed reassessment proceedings for Zydus Healthcare Limited, ruling that audit objections alone cannot justify reopening assessments beyond three years.
- The Court emphasized that without new evidence or documents revealing escaped income, the reassessment under Section 148 was invalid.
- It distinguished between audit objections as mere information and the statutory requirements under Section 149(1)(b) for reassessment, asserting that a change of opinion does not warrant reopening.
- This ruling reinforces limitations on tax authorities' powers, potentially impacting future reassessments based solely on audit findings.
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