https://www.taxtmi.com/caselaws?id=413860 ITAT held that the AO's belief of escaped income was based on a wrong factual assumption - namely that funds deposited in a third-party company were routed to the taxpayer as share subscription - which the Pr. CIT found absent. Consequently, issuance of notice under section 148 and the reassessment dated 29.12.2017 were nullities, and the Pr. CIT's action under section 263 to interfere with that reassessment lacked jurisdiction. Decision in favor of the assessee. en-us Wed, 13 Oct 2021 00:00:00 +0530 Sat, 20 Sep 2025 11:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=413860 ITAT held that the AO's belief of escaped income was based on a wrong factual assumption - namely that funds deposited in a third-party company were routed to the taxpayer as share subscription - which the Pr. CIT found absent. Consequently, issuance of notice under section 148 and the reassessment dated 29.12.2017 were nullities, and the Pr. CIT's action under section 263 to interfere with that reassessment lacked jurisdiction. Decision in favor of the assessee. Case-Laws Income Tax Wed, 13 Oct 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=413860