2017 (7) TMI 621 - SC ORDER

Validity of reopening of assessment - Held that:- The Special Leave Petition is dismissed. HC order confirmed [2017 (4) TMI 188 - DELHI HIGH COURT]

HC has held that to require the Revenue to disclose further details regarding the nature of documents or contents thereof would be virtually rewriting the conditions in section 147. After all, Section 147 merely authorises the issuance of notice to reopen with conditions. If the Court were to dictate the manner and contents of what is to be written, the statutory conditions would be added as it were. In this context, it needs to be emphasized that the court would interpret the statute as they stand in their own terms, but at the same time being conscious of the rights of the citizens.