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The ITAT invalidated the reopening of assessment under section 147/148 due to the Assessing Officer's failure to independently apply his mind before issuing the notice. The AO had merely relied on information from the Directorate of Income-tax (Systems) or Investigation Wing's report from search operations on Kundu group without verifying whether the transactions were already reported by the assessee. The Tribunal noted that some transactions claimed to be unreported were actually part of the assessee's filed computation. Additionally, if the reopening was based on search and seizure operations of Kundu group, section 153C should have been invoked instead of section 147/148. The Tribunal sustained the assessee's jurisdictional challenge to the assumption of jurisdiction.
The ITAT invalidated the reopening of assessment under section 147/148 due to the Assessing Officer's failure to independently apply his mind before issuing the notice. The AO had merely relied on information from the Directorate of Income-tax (Systems) or Investigation Wing's report from search operations on Kundu group without verifying whether the transactions were already reported by the assessee. The Tribunal noted that some transactions claimed to be unreported were actually part of the assessee's filed computation. Additionally, if the reopening was based on search and seizure operations of Kundu group, section 153C should have been invoked instead of section 147/148. The Tribunal sustained the assessee's jurisdictional challenge to the assumption of jurisdiction.
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