https://www.taxtmi.com/caselaws?id=445843 ITAT Delhi quashed reassessment proceedings initiated under Section 147/148 for AY 2009-10. The original assessment was completed under Section 143(3), requiring Revenue to meet higher burden under first proviso for reopening after four years. AO failed to provide transaction-wise details of alleged fictitious losses through NSE platform misuse, acting merely on investigation wing's information without applying mind to basic facts. Pr.CIT's approval was perfunctory. The jurisdiction assumption suffered multiple defects, making the Section 148 notice invalid and subsequent reassessment bad in law. Appeal allowed. en-us Thu, 17 Aug 2023 00:00:00 +0530 Mon, 20 Nov 2023 20:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445843 ITAT Delhi quashed reassessment proceedings initiated under Section 147/148 for AY 2009-10. The original assessment was completed under Section 143(3), requiring Revenue to meet higher burden under first proviso for reopening after four years. AO failed to provide transaction-wise details of alleged fictitious losses through NSE platform misuse, acting merely on investigation wing's information without applying mind to basic facts. Pr.CIT's approval was perfunctory. The jurisdiction assumption suffered multiple defects, making the Section 148 notice invalid and subsequent reassessment bad in law. Appeal allowed. Case-Laws Income Tax Thu, 17 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445843