https://www.taxtmi.com/caselaws?id=448462 The ITAT Delhi held that reassessment proceedings under section 148 were invalid regarding unexplained investments in NCDs. The assessee had subscribed to NCDs in 2014, earned interest which was properly offered to tax in subsequent years, and redeemed the NCDs in 2015. The funds were then transferred to Singapore after obtaining proper forms 15CB and 15CA. The tribunal found that the assessee had merely repatriated previously invested amounts with no new income accruing in assessment year 2017-18. Since the Assessing Officer failed to examine relevant records showing interest was duly taxed and there was no income escapement, the section 148 notice was deemed void ab initio, rendering the assessment a nullity. The assessee's appeal was allowed. en-us Wed, 17 Jan 2024 00:00:00 +0530 Fri, 19 Jan 2024 08:51:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448462 The ITAT Delhi held that reassessment proceedings under section 148 were invalid regarding unexplained investments in NCDs. The assessee had subscribed to NCDs in 2014, earned interest which was properly offered to tax in subsequent years, and redeemed the NCDs in 2015. The funds were then transferred to Singapore after obtaining proper forms 15CB and 15CA. The tribunal found that the assessee had merely repatriated previously invested amounts with no new income accruing in assessment year 2017-18. Since the Assessing Officer failed to examine relevant records showing interest was duly taxed and there was no income escapement, the section 148 notice was deemed void ab initio, rendering the assessment a nullity. The assessee's appeal was allowed. Case-Laws Income Tax Wed, 17 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448462