Delhi High Court Quashes Reassessment Against Sports Events Company As Time-Barred, Calls It Change of Opinion
Kapil Dhyani
31 March 2026 9:57 PM IST
The Delhi High Court has quashed reassessment proceedings against a Delhi-based sports events company, holding that the notice issued on July 30, 2022 was time-barred and that reopening the case on issues already scrutinized amounted to a mere change of opinion, rendering the entire exercise invalid.
A Division Bench of Justices Dinesh Mehta and Vinod Kumar allowed the writ petition filed by the company, setting aside the reassessment notice, subsequent orders, and the ex-parte assessment order raising a demand of over Rs. 96 crore.
Petitioner had filed its return for Assessment Year (AY) 2017-18 declaring losses. Its case was selected for scrutiny, and after a detailed examination of issues including share capital, investments, and expenses, an assessment order under Section 143(3) of the Income Tax Act, 1961 was passed in 2019.
Subsequently, the Assessing Officer initiated reassessment proceedings based on a tax evasion complaint. Notices were issued under Sections 148 and 148A, eventually culminating in an ex-parte assessment order and demand notice in December 2025.
The High Court held that the reassessment notice dated July 30, 2022 was issued beyond the permissible limitation period, even after accounting for extensions under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 (TOLA) and the Supreme Court's rulings in Union of India v. Ashish Agarwal and Union of India v. Rajeev Bansal.
Referring to the computation of the “surviving period”, the Court noted that the Revenue had only 16 days available after June 5, 2022, and the last date to issue a valid notice was June 21, 2022. Since the impugned notice was issued on July 30, 2022, it was held to be time-barred.
The Bench also observed that the issues forming the basis of reassessment, such as share capital and investments, had already been thoroughly examined during the original scrutiny assessment.
In such circumstances, reopening the assessment on the same material amounted to a mere change of opinion, which is impermissible in law.
Holding the initial notice to be void, the Court ruled that all consequential actions, including the order under Section 148A(d), the reassessment notice, and the final assessment order, were liable to be quashed.
The writ petition was accordingly allowed.
For Petitioner: Senior Advocate Ajay Vohra, with Advocates Rohit Jain, Saksham Singhal and Kashish Harwani
For Respondents: SSC Sunil Agarwal, with JSCs Monica Benjamin, Gibran Naushad, Advocates Rohit Chakraborty and Nancy Jain