New Delhi Television Ltd. v. DCIT

116 Taxmann.com 151Supreme Court of India2020#734 most cited

What is New Delhi Television Ltd. v. DCIT authority for?

Reassessment initiated under Section 147/148 is invalid if the Assessing Officer relies on material obtained post-recording of reasons, or if it amounts to a mere change of opinion on facts fully and truly disclosed by the assessee during the original assessment. An assessee's obligation extends only to the full and true disclosure of primary facts, not to provide further assistance or inferences.

139

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2012 to 2026.

Also referred to as

New Delhi Television Ltd. v. DCIT · Section 147 · Section 148 · Income Tax Act 1961 · reassessment validity · mere change of opinion · full and true disclosure · primary facts · reasons recorded · material post-recording · Kelvinator principle · first proviso to section 147

Also reported as

424 ITR 607271 Taxmann 1

Issues it is cited on

Judgments citing New Delhi Television Ltd. v. DCIT