Sikkim HC says Audit Objection Alone Cannot Sustain Extended Income-Tax Reassessment

The Court held that reassessment beyond three years requires the Assessing Officer to possess credible books of account, documents or evidence meeting Section 149(1)(b). An audit objection alone cannot fulfil that requirement or authorise a review of an assessment already completed. Applying this reasoning across three assessment years, the Court quashed the impugned reassessment proceedings and orders.