Garden Silk Mills Pvt. Ltd. v. DCIT
240 ITR 628High Court1999#6762 most cited
What is Garden Silk Mills Pvt. Ltd. v. DCIT authority for?
Reassessment proceedings under Section 147 initiated based on a mere change of opinion or without tangible material are invalid. The Assessing Officer must have a "reason to believe" that income has escaped assessment, supported by evidence beyond a re-evaluation of the original assessment's material.
17
judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2016 to 2025.
Also referred to as
Garden Silk Mills Pvt. Ltd. v. DCIT · Section 147 · Section 148 · reason to believe · change of opinion · tangible material · escapement of income · regular assessment · notice under section 148