Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Reopening under section 147 hinged on whether the AO had independent "reasons to believe" or merely adopted borrowed satisfaction from the Insight Portal; the Tribunal found no nexus between materials on record and the information relied upon, holding the AO failed to apply independent mind, so the re-opening was invalid-reassessment order under section 147 quashed. Because the foundational notice was quashed, the Tribunal declined to decide the substantive allegation of bogus long-term capital gains, resulting in a decision for the assessee. - ITAT
Reopening under section 147 hinged on whether the AO had independent "reasons to believe" or merely adopted borrowed satisfaction from the Insight Portal; the Tribunal found no nexus between materials on record and the information relied upon, holding the AO failed to apply independent mind, so the re-opening was invalid-reassessment order under section 147 quashed. Because the foundational notice was quashed, the Tribunal declined to decide the substantive allegation of bogus long-term capital gains, resulting in a decision for the assessee. - ITAT
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