https://www.taxtmi.com/caselaws?id=447890 Delhi HC quashed reassessment proceedings u/s 147 initiated based on audit objections regarding deduction u/s 80-IC. Court held AO failed to apply independent mind, merely relied on auditor's findings without examining reply to audit objection. Since original assessment was completed after scrutiny where same issue was examined, petitioner had disclosed all material facts. Reassessment after four years required AO to specify undisclosed material facts, which was absent. Proceedings suffered from borrowed satisfaction, inadequate reasons to believe, and amounted to change of opinion. Notice and rejection order quashed. en-us Tue, 12 Dec 2023 00:00:00 +0530 Mon, 08 Jan 2024 09:13:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=447890 Delhi HC quashed reassessment proceedings u/s 147 initiated based on audit objections regarding deduction u/s 80-IC. Court held AO failed to apply independent mind, merely relied on auditor's findings without examining reply to audit objection. Since original assessment was completed after scrutiny where same issue was examined, petitioner had disclosed all material facts. Reassessment after four years required AO to specify undisclosed material facts, which was absent. Proceedings suffered from borrowed satisfaction, inadequate reasons to believe, and amounted to change of opinion. Notice and rejection order quashed. Case-Laws Income Tax Tue, 12 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=447890