Limits of Reassessment Disclosure

The judgment of the Delhi High Court in the writ petition filed by M/s MHJ Metaltechs Pvt. Ltd. addresses an increasingly litigated question under the post-2021 reassessment regime—how far the Assessing Officer is required to go in disclosing the basis of a proposed reopening at the pre-notice stage. In clarifying the distinction between “information suggesting escapement of income” and the underlying material forming the basis of such belief, the Court delineates the contours of procedural fairness under Section 148A while simultaneously preserving the staged structure of reassessment proceedings. The ruling assumes added significance in light of the continuity of this framework under the New Income-tax Act, 2025, and offers important guidance on the limits of disclosure obligations at the threshold stage of reopening.