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of Reopening of assessment u/s 147 was invalid as AO reopened with non-application of mind and higher authorities granted approval u/s 151 mechanically without verifying facts. Assessee, a non-resident Australian entity, received fees from another non-resident for telecasting rights, not taxable in India. AO erroneously assumed assessee had income generating activities and failed to file return. DRP disposed objections referring to non-filing of TDS return despite AO admitting no remittances or TDS. DRP failed to discharge duties properly by not considering facts and law. Reopening lacked jurisdiction, hence quashed. Decided in assessee's favor.
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