https://www.taxtmi.com/caselaws?id=445095 The ITAT Delhi quashed the reopening of assessment u/s 147 for AY 2013-14, finding the reasons recorded by the AO contained numerous factual inaccuracies and mistakes. The AO incorrectly stated the assessee failed to file TDS returns u/s 194E and 195, when in fact no such returns were required as the assessee received payments rather than making remittances abroad. The reasons showed no nexus with tangible material on record. Both Additional CIT and CIT granted approval u/s 151 without proper examination. The DRP also erred by relying on the same incorrect facts despite the AO admitting mistakes. The tribunal held the reopening was invalid and decided in favor of the assessee. en-us Fri, 27 Oct 2023 00:00:00 +0530 Tue, 31 Oct 2023 09:55:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445095 The ITAT Delhi quashed the reopening of assessment u/s 147 for AY 2013-14, finding the reasons recorded by the AO contained numerous factual inaccuracies and mistakes. The AO incorrectly stated the assessee failed to file TDS returns u/s 194E and 195, when in fact no such returns were required as the assessee received payments rather than making remittances abroad. The reasons showed no nexus with tangible material on record. Both Additional CIT and CIT granted approval u/s 151 without proper examination. The DRP also erred by relying on the same incorrect facts despite the AO admitting mistakes. The tribunal held the reopening was invalid and decided in favor of the assessee. Case-Laws Income Tax Fri, 27 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445095