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    <title>2017 (7) TMI 371 - DELHI HIGH COURT</title>
    <link>https://www.taxtmi.com/caselaws?id=345259</link>
    <description>The Delhi HC upheld ITAT&#039;s decision that reopening of assessment under Section 147 was invalid. The AO erroneously assumed the assessee had not filed a return when one was actually filed. The court found no tangible link between available material and formation of reasons to believe income had escaped assessment. Information from Investigation Wing alone was insufficient without further inquiry by the AO. Additionally, the AO incorrectly added Rs. 1.13 crore instead of Rs. 78 lakh as mentioned in reopening reasons, without proper explanation. The court concluded the AO deprived himself of conducting proper inquiry due to incorrect assumptions, making the reopening procedurally flawed and legally invalid.</description>
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    <pubDate>Fri, 07 Jul 2017 00:00:00 +0530</pubDate>
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      <title>2017 (7) TMI 371 - DELHI HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=345259</link>
      <description>The Delhi HC upheld ITAT&#039;s decision that reopening of assessment under Section 147 was invalid. The AO erroneously assumed the assessee had not filed a return when one was actually filed. The court found no tangible link between available material and formation of reasons to believe income had escaped assessment. Information from Investigation Wing alone was insufficient without further inquiry by the AO. Additionally, the AO incorrectly added Rs. 1.13 crore instead of Rs. 78 lakh as mentioned in reopening reasons, without proper explanation. The court concluded the AO deprived himself of conducting proper inquiry due to incorrect assumptions, making the reopening procedurally flawed and legally invalid.</description>
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      <pubDate>Fri, 07 Jul 2017 00:00:00 +0530</pubDate>
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