Reopening in the case of Assessee was done based on information available on insight portal regarding accommodation entries and huge cash deposits. The issue before the High Court was whether a change in the name of the Assessee resulted in loss of jurisdiction. The High Court held that the Assessee was still within the same territorial jurisdiction. A name change does not automatically divest the AO of his powers. The other issue before the High Court was whether the AO has ‘reasons to believe’ that income had escaped assessment. The High Court held that no evidence was referred to while recording reasons and hence the reassessment notice was quashed. SLP dismissed. (AY. 2017-18)
ITO v. O3 Developers (P.) Ltd. [2026] 486 ITR 269 / 182 taxmann.com 373 (SC) Editorial : O3 Developers (P.) Ltd v.ITO [2025] 174 taxmann.com 1028 /(2026) 486 ITR 245 (Guj)(HC)
S. 147: Reassessment-Cash credits-Change in name-Territorial jurisdiction-Information on Insight portal-Held, mere change in name does not lead to change in jurisdiction-Held, no evidence relied on during recording of reasons-Reopening quashed-SLP dismissed. [S. 68, 124(1),148, Art. 136]
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