Corporate TaxArticle·9 April 2026
Reassessment Foundation Collapse
By J the App
Executive Summary
A reassessment cannot survive where its foundational facts are wrong.
The Delhi High Court quashed the Section 148 notice against RRPR Holdings, holding that the Revenue proceeded on an incorrect factual premise regarding a loan allegedly masking share transfer.
The Supreme Court, while not entering merits, effectively sealed the outcome by dismissing the SLP due to inordinate delay—thereby lending finality to a strong taxpayer precedent on reassessment discipline.
Issues for Determination
The central issue was whether reassessment proceedings under Section 148 of the Income Tax Act, 196...
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