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The ITAT quashed reassessment proceedings initiated under s. 147 where the AO had reopened assessment based solely on information from the Investigation Wing without independent application of mind. The Tribunal found that the assessee had fully disclosed all material facts during original assessment proceedings, substantiating the identity and creditworthiness of the loan creditor. The AO had already obtained information under s. 133(6) from Cambridge Financial Services Pvt. Ltd. during the original assessment completed under s. 143(3). Following Punia Capital (P.) Ltd., the ITAT held that reopening after four years requires failure to disclose material facts, which was absent in this case, as the AO relied merely on "reason to believe" without establishing any non-disclosure by the assessee.
The ITAT quashed reassessment proceedings initiated under s. 147 where the AO had reopened assessment based solely on information from the Investigation Wing without independent application of mind. The Tribunal found that the assessee had fully disclosed all material facts during original assessment proceedings, substantiating the identity and creditworthiness of the loan creditor. The AO had already obtained information under s. 133(6) from Cambridge Financial Services Pvt. Ltd. during the original assessment completed under s. 143(3). Following Punia Capital (P.) Ltd., the ITAT held that reopening after four years requires failure to disclose material facts, which was absent in this case, as the AO relied merely on "reason to believe" without establishing any non-disclosure by the assessee.
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