Chetan Sabharwal v. Assistant Commissioner of Income Tax Circle 28(1) New Delhi
2026 INSC 116328 October 202615 min read
Supreme Court Upholds Reassessment Based on Post-Assessment Investigation Report and Share Overvaluation
The Supreme Court held that a post-assessment investigation report constitutes tangible material, and a non-speaking assessment order does not amount to a "change of opinion."
Case Snapshot
- Case Name
- Chetan Sabharwal v. Assistant Commissioner of Income Tax Circle 28(1) New Delhi
- Citation
- 2026 INSC 1163
- Bench
- Justice J.B. Pardiwala & Justice K. Vinod Chandran
- Date of Judgment
- October 28, 2026
- Area of Law
- Income Tax Act, 1961 – Reassessment – Sections 147 and 148 – Reason to Believe – Change of Opinion
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