https://www.taxtmi.com/caselaws?id=448826 ITAT Mumbai held that reopening proceedings u/s 147 r.w.s. 148 were invalid where AO taxed property sale transactions in individual assessee's hands despite evidence showing transactions were between two partnership firms. AO ignored partnership deed, PAN details, and developer agreement filed during assessment proceedings. The tribunal ruled that since sale deed was between partnership firms and not involving assessee individually, AO should have issued notice to partnership firm instead. Reasons recorded by AO were based on incorrect assumptions from ITS records without proper verification. Entire proceedings u/s 148 were quashed as invalid and assessee's appeal was allowed. en-us Mon, 29 Jan 2024 00:00:00 +0530 Wed, 31 Jan 2024 08:26:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448826 ITAT Mumbai held that reopening proceedings u/s 147 r.w.s. 148 were invalid where AO taxed property sale transactions in individual assessee's hands despite evidence showing transactions were between two partnership firms. AO ignored partnership deed, PAN details, and developer agreement filed during assessment proceedings. The tribunal ruled that since sale deed was between partnership firms and not involving assessee individually, AO should have issued notice to partnership firm instead. Reasons recorded by AO were based on incorrect assumptions from ITS records without proper verification. Entire proceedings u/s 148 were quashed as invalid and assessee's appeal was allowed. Case-Laws Income Tax Mon, 29 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448826