#assessment reopening

Assessing officers cannot invoke Section 148 to reopen returns when the material originates from a search conducted before 31 March 2021; such cases fall within the block period of Section 153C. This limits revenue’s power to reassess older assessments and guides practitioners on the correct statutory basis. Taxpayers with assessments from that period are protected from improper reopening.

The Gujarat High Court set aside a 2019 Section 148 notice, ruling that without new, concrete material a tax authority cannot reopen an assessment merely on a revised opinion. This reinforces that any reassessment must be backed by fresh evidence, protecting taxpayers from arbitrary reopening.