https://www.taxtmi.com/caselaws?id=448674 ITAT Delhi quashed reassessment notice u/s 147 issued beyond four years based on Client Code Modification allegations. The tribunal held that AO failed to dispose of assessee's objections through speaking order, violating SC guidelines in GKN Driveshafts case. The reasons recorded lacked specific material linking the assessee to alleged malpractices by brokers in CCM facility misuse. Survey findings from Ahmedabad wing were vague without identifying specific brokers involved. The assessee's broker confirmed CCM was due to punching errors, not profit shifting. Following Globus Power Generation precedent, tribunal found no material evidence of malafide purpose or tax evasion, establishing no live link between available material and AO's inference of income escapement. en-us Tue, 23 Jan 2024 00:00:00 +0530 Wed, 15 Apr 2026 15:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448674 ITAT Delhi quashed reassessment notice u/s 147 issued beyond four years based on Client Code Modification allegations. The tribunal held that AO failed to dispose of assessee's objections through speaking order, violating SC guidelines in GKN Driveshafts case. The reasons recorded lacked specific material linking the assessee to alleged malpractices by brokers in CCM facility misuse. Survey findings from Ahmedabad wing were vague without identifying specific brokers involved. The assessee's broker confirmed CCM was due to punching errors, not profit shifting. Following Globus Power Generation precedent, tribunal found no material evidence of malafide purpose or tax evasion, establishing no live link between available material and AO's inference of income escapement. Case-Laws Income Tax Tue, 23 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448674