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of <h1>Assessment reopening quashed due to lack of concrete evidence linking to income escapement under section 147</h1> <h3>Umang Webtech Pvt. Ltd. Versus Income Tax Officer</h3> Umang Webtech Pvt. Ltd. Versus Income Tax Officer - TMI The Appellate Tribunal (ITAT Kolkata) allowed the assessee's appeal against the reopening of assessment for AY 2014-15 under section 147/148 of the Income Tax Act. The reopening was based on the allegation that the assessee received Rs. 55,00,000 from Shri Swapan Das during FY 2013-14, which the assessee denied, supported by bank statements evidencing non-receipt of such amount. The Tribunal held that the reopening was 'without any tangible material' and lacked a 'live link' to escapement of income, rendering it 'bad in law.' It further observed that the ld. CIT(A) failed to appreciate the facts correctly. Consequently, the Tribunal quashed the reopening proceedings under section 147 and the assessment framed under section 143(3)/147, stating: 'the reopening of assessment has no basis.' The appeal was allowed accordingly.
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