In [2023] 456 ITR 709 (Del) the reasons to believe were provided to the taxpayer after a gap of one and a half years.
And in the second disaster the reassessment proceedings were actually initiated just seven days before the limitation was set to expire.
The taxpayer challenged both notice and reassessment on gross violation of principles of natural justice and demanded for quashing of the two relying on SC decisions.
On the delay the department assigned reason as state of confusion over jurisdiction to exercise power of reassessment in view of faceless scheme introduction.
Even with this callous approach of the department the High Court resumed reassessment by calling upon AO to entertain fresh objections and their speedy disposal.
This may not be a single case instance of confusion over jurisdiction and further the responsibility lie upon the CBDT to have issued appropriate instructions in advance in the absence of which there should have been no reinitiating reassessment in the scenario.