Reassessment and Special Audit

In a landmark ruling on post-search reassessment and special audit powers, the Delhi High Court has critically examined the Revenue’s attempt to reopen concluded assessments and direct a special audit in the absence of demonstrable complexity or incriminating material. 

The case underscores strict jurisdictional thresholds for reassessment beyond limitation periods and reinforces that special audit under Section 142(2A) cannot be deployed as a tool for fishing inquiries or timeline extension.