Assistant Commissioner Of Income Tax vs Rajesh Jhaveri Stock Brokers Pvt. Ltd

The Supreme Court held that the Gujarat High Court erred in allowing the writ petition filed by the respondent under Section 148 of the Income Tax Act, 1961, as the case was distinguishable from Adani Exports v. Deputy Commissioner of Income Tax, which pertained to Section 143(3). The Court emphasized that the initiation of reassessment proceedings under Section 147 was valid given the failure to meet conditions under Section 36(1)(vii) and Section 36(2). Consequently, the appeal by the revenue was allowed, overturning the High Court's decision.