https://www.taxtmi.com/caselaws?id=433843 The HC quashed the reopening of assessment u/s 147, finding the AO's reasons to believe were based on a non-existent property transaction. The petitioner had purchased land in Pali, not Delhi property as alleged by the AO. The transaction was properly disclosed in audited financial statements and income tax returns. Despite the petitioner's detailed objections clarifying the error, authorities failed to rectify the mistake and instead attempted to justify reopening on new grounds. The HC held that proceedings were based on conjectures without tangible evidence, constituting borrowed satisfaction. The reopening notice, reasons to believe, and order rejecting objections were all founded on incorrect assumptions about a fictitious transaction. en-us Wed, 08 Feb 2023 00:00:00 +0530 Wed, 14 May 2025 12:03:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=433843 The HC quashed the reopening of assessment u/s 147, finding the AO's reasons to believe were based on a non-existent property transaction. The petitioner had purchased land in Pali, not Delhi property as alleged by the AO. The transaction was properly disclosed in audited financial statements and income tax returns. Despite the petitioner's detailed objections clarifying the error, authorities failed to rectify the mistake and instead attempted to justify reopening on new grounds. The HC held that proceedings were based on conjectures without tangible evidence, constituting borrowed satisfaction. The reopening notice, reasons to believe, and order rejecting objections were all founded on incorrect assumptions about a fictitious transaction. Case-Laws Income Tax Wed, 08 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=433843