https://www.taxtmi.com/caselaws?id=448209 The ITAT Delhi quashed the reopening of assessment under section 147, finding that the AO failed to establish "reasons to believe" from mere "reasons to suspect." The AO blindly relied on investigation wing reports regarding accommodation entries from an entry operator without applying independent mind or justifying the transition from suspicion to belief. The AO used a template format to reopen all beneficiary cases, incorrectly including the assessee company which was actually providing accommodation entries rather than receiving them. The CIT(A) erroneously sustained the reopening through general discussion. The information was specific to the entry operator but not against the assessee. Decision favored the assessee against revenue. en-us Thu, 11 Jan 2024 00:00:00 +0530 Sat, 13 Jan 2024 13:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448209 The ITAT Delhi quashed the reopening of assessment under section 147, finding that the AO failed to establish "reasons to believe" from mere "reasons to suspect." The AO blindly relied on investigation wing reports regarding accommodation entries from an entry operator without applying independent mind or justifying the transition from suspicion to belief. The AO used a template format to reopen all beneficiary cases, incorrectly including the assessee company which was actually providing accommodation entries rather than receiving them. The CIT(A) erroneously sustained the reopening through general discussion. The information was specific to the entry operator but not against the assessee. Decision favored the assessee against revenue. Case-Laws Income Tax Thu, 11 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448209