Understanding of Law and Procedure of Reassessment

This book provides a comprehensive analysis of the reassessment provisions under the Income-tax Act, 1961, as amended by the Finance Act, 2025. It covers key aspects such as the issuance and service of notices, approval requirements, time limits, and the validity of notices under specific circumstances.

The book also discusses the implications of provisions like Sections 148 and 148A, as well as the procedural specifics of reassessment. Additionally, it offers practical guidance for professionals on effectively presenting reassessment cases before Revenue and Appellate Authorities.

1. Introduction
2. Income Escaping Assessment [Section 147]
3. Issue of Notice Under section 148 where Income has Escaped Assessment [Section 148 : As substituted by the Finance (No. 2) Act, 2024, with effect from 01.09.2024]
4. Issue of Notice under section 148 Where Income has Escaped Assessment [Section 148 : As applicable upto 31.08.2024]
5. Issue and Service of Notice under section 148
6. Notices under section 148 barred by Limitation
7. Notice in the Name of Deceased Assessee in Reassessment Proceedings
8. Reassessment – Notice Against Non-existent Entity – Validity
9. Notice Deemed to be Valid in Certain Circumstances [Section 292BB]
10. Issuance of Notice Under Section 143(2) in Reassessment Proceedings
11. Procedure before issuance of notice under section 148 [Section 148A : Applicable with effect from 01.09.2024]
12. Procedure before issuance of notice under section 148 [Section 148A : Applicable upto 31.08.2024]
13. Prior approval for assessment, reassessment, or recomputation in certain Cases [Section 148B]
14. Time Limit for Notices under Sections 148 and 148A [Section 149 : Applicable from 01.09.2024]
15. Time Limit for Issue of Notice Under Section 148 [Section 149 : Applicable from 31.08.2024]
16. Provision for Cases where Assessment is in Pursuance of an Order on Appeal, etc. [Section 150]
17. Sanction for Issue of Notice under Section 148 [Section 151]
18. Faceless Assessment of Income Escaping Assessment [Section 151A]
19. Other Provisions [Section 152]
20. Time Limit for Completion of Assessment, Reassessment and Re-computation [Section 153]
21. Effect of Re-opening the Assessment Based on Wrong Facts or Conclusions
22. Reopening of Assessment and Maintainability of Writ Petition
23. Reopening beyond 4 years’ failure to disclose fully and truly material facts necessary for assessment
24. Concept of Reason to believe
25. Doctrine of Change of Opinion
26. Offences and Prosecutions
27. Specimen of Reasons recorded for Reopening of Assessment
28. Important Board’s Circulars and Instructions
29. Cases where Initiating Reassessment Proceedings Justified
30. Cases where initiating reassessment proceedings not justified
31. Cases where Reassessment Proceedings Justified on the Basis of Informations Received from other Agencies
32. Cases where Reassessment Proceedings not Justified on the Basis of Informations Received from other Agencies
33. Important case law on Reassessment