Supreme Court Rejects Reassessments Without Mandatory Scrutiny Notices

Information requests cannot replace a mandatory scrutiny notice in income-tax reassessment, the Supreme Court held on 28 October 2026 while dismissing five Revenue appeals.

Judge / Bench — Justices Sanjay Kumar and Sanjeev Sachdeva; judgment by Justice Sanjeev Sachdeva.

In the Orissa Mining Corporation and connected Bijoy Kishore Mohanty cases, no Section 143(2) notice had been issued. Participation cannot cure that complete absence under Section 292BB, the Court held. Reiterating an earlier return in response to Section 148 does not waive the notice, and a Section 142(1) request for information is no substitute.

Advocates appearing — Appellants and respondents — Not named in the judgment.