Reassessment Reset Doctrine

In a procedural yet significant ruling, the High Court has reaffirmed that reassessment proceedings initiated under the transitional regime post-2021 amendments must strictly adhere to the Supreme Court’s framework in Ashish Agarwal and Rajeev Bansal.

Any deviation, particularly at the stage of disposal of objections under Section 148A(d), renders the proceedings vulnerable to being reset.

The decision reinforces that reassessment is not merely a jurisdictional trigger but a process-driven exercise requiring strict procedural fidelity.