Reopening without Asset

In a precise and jurisdiction-focused ruling, the Delhi High Court has reaffirmed that extended reassessment timelines are not automatic, they are conditional.

Where the Assessing Officer fails to record the existence of an “asset,” invocation of the 10-year window collapses.

The judgment reinforces that limitation is not procedural, it is jurisdictional, and defects therein cannot be cured post facto.

Even more significantly, the Court entertained the writ despite completion of assessment, underscoring that jurisdictional defects go to the root.