Gujarat High Court Quashes Income Tax Reassessment, Says AO Cannot Conduct Roving Inquiry Under Section 148A

The Gujarat High Court has quashed the reopening of an income tax assessment under Section 148A of the Income Tax Act, holding that the Assessing Officer cannot initiate reassessment proceedings by conducting a roving or fishing inquiry.

The Court observed that the assessee had already furnished all relevant details sought by the tax authorities and that reopening the assessment without fresh tangible material amounted to an abuse of process.

The Court said Section 148A does not permit reassessment merely on suspicion or for verification purposes.

It held that reassessment proceedings must be based on specific information suggesting income escapement, and not on a general desire to re-examine concluded assessments.