Reassessment Without Basis

In a sharp reaffirmation of reassessment discipline, the Supreme Court has declined to interfere with a Delhi High Court ruling that invalidated reopening notices grounded in generic survey findings and assumptions of continuity.

While the SLP was dismissed on delay and merits, the Court notably kept the question of law open, preserving room for future adjudication.

The underlying High Court judgment delivers a clear message:

Reassessment cannot be sustained on extrapolated facts, each assessment year must stand on its own factual foundation.