What are some important judicial precedents related to reassessment proceedings?

There have been several significant court judgments that have shaped the jurisprudence around reassessment proceedings. For instance, in the case of Arihant Tiles & Marbles Pvt. Ltd. v. DCIT (2018) 92 taxmann.com 242 (Guj.), the Gujarat High Court held that the Assessing Officer must have a ‘live link’ or tangible material to form a belief of income escaping assessment. Similarly, in the case of CIT v. Kelvinator of India Ltd. (2010) 320 ITR 561 (SC), the Supreme Court ruled that reassessment based on a mere change of opinion is not permissible.

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