Delhi HC quashes reassessment under Section 148 due to non-fulfillment of Section 150 conditions

The Delhi High Court ruled that reassessment under Section 148 of the Income Tax Act was invalid as conditions under Section 150 were not fulfilled.

A 2006 search led to ₹7 crores being disclosed, but only ₹20 lakhs was included in the 2007-08 income return, resulting in additions to the income of two directors.

In 2015, reassessment was proposed under Section 148, citing earlier findings, but the Court found no conclusive directions for such action in prior orders.

The Court held that reassessment violated the time limit under Section 149 and lacked grounds under Section 150, making it unsustainable.