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ITAT quashed the reopening of assessment under section 147 r.w.s. 148 of the Act due to fundamental procedural defects. The AO's reasons for reopening were deemed scanty, vague, and ambiguous, containing conflicting statements about alleged fictitious profit in equity/derivative trading and exempted Long Term Capital Gain. The Tribunal found no independent application of mind by the AO, who merely relied on received information without verifying transaction details, payment modes, or counterparties. Additionally, the PCIT's approval was determined to be mechanical rather than substantive, as it lacked recorded reasoning or satisfaction. The assessment was set aside due to both non-application of mind and invalid approval.
ITAT quashed the reopening of assessment under section 147 r.w.s. 148 of the Act due to fundamental procedural defects. The AO's reasons for reopening were deemed scanty, vague, and ambiguous, containing conflicting statements about alleged fictitious profit in equity/derivative trading and exempted Long Term Capital Gain. The Tribunal found no independent application of mind by the AO, who merely relied on received information without verifying transaction details, payment modes, or counterparties. Additionally, the PCIT's approval was determined to be mechanical rather than substantive, as it lacked recorded reasoning or satisfaction. The assessment was set aside due to both non-application of mind and invalid approval.
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