The Constitutional Guardrails of Reassessment

Today's note on J the app is the decision in Amitkumar Chandulal Rajani (SLP No. 318/2026, order dated 06.01.2026) which marks a reaffirmation of first principles governing reassessment jurisdiction under the Income-tax law. Emerging from proceedings initiated under Section 148 of the Income-tax Act, 1961, the case scrutinised the validity of reopening founded upon third-party search material, alleged non-filing of returns, and purported escapement of income. The Gujarat High Court’s intervention, subsequently left undisturbed by the Supreme Court, underscores that reassessment is not an administrative formality but a jurisdictional exercise conditioned upon strict statutory discipline, independent application of mind, and adherence to natural justice.