Reassessment notice based on transactions from an unrelated financial year is invalid.

The petitioner filed his return for A.Y. 2023–24 declaring income of ₹30,12,070.

Following a search in the Avirat Group and Brahma Finance Group cases—not a search of the petitioner—the Revenue issued a notice under Section 148 dated 30 March 2026, relying on a satisfaction note and material seized from a third party.

The petitioner objected, arguing that the document was unsigned and unverified and recorded transactions for F.Y. 2021–22, not F.Y. 2022–23 relevant to the assessment year under reassessment.

The Revenue rejected the objections, and the petitioner challenged the notice by writ petition.

Whether the notice under Section 148 for A.Y. 2023–24 could stand when the material relied upon related to transactions in F.Y. 2021–22 rather than the relevant F.Y. 2022–23.

Whether the notice could be sustained when it relied on an unsigned and unauthenticated third-party record and the petitioner’s identification with the person named in that record was conjectural.

The Court considered Sections 147, 148, 148A and 151 of the Income Tax Act, 1961, in the context of the Revenue’s reassessment action and the approval and satisfaction underlying the notice.

The judgment’s operative principle was that a reassessment notice cannot be sustained when its jurisdictional foundation rests on an erroneous reading of the underlying material—particularly where the material does not relate to the relevant assessment year and the Revenue has not independently verified the facts.

The Court cited no precedent.

The Court found that the sole confirmation of accounts was dated 1 April 2022 and covered 1 April 2021 to 31 March 2022, corresponding to F.Y. 2021–22 and A.Y. 2022–23—not the year relevant to the impugned notice.

The figures attributed by the Revenue to A.Y. 2023–24 matched entries from that earlier financial year, demonstrating that transactions had been transposed between years.

The document was also unsigned and unauthenticated, and the identification of the petitioner was based on conjecture.

The Revenue’s failure to verify the facts independently meant the notice was premised on incorrect facts.

It quashed and set aside the notice, allowed the petition, and did not grant any separate relief beyond that order.