https://www.taxtmi.com/caselaws?id=448957 ITAT Delhi held that reopening of assessment under section 148 was invalid due to lack of proper application of mind by AO. Despite receiving information from DDIT(Inv.) about unexplained investment of over 15 crores in house property construction, AO failed to establish live link between materials and belief that income escaped assessment. Court noted factual inconsistencies in recorded reasons, including erroneous premise that assessee had not filed return when return was actually filed. AO's reliance solely on investigation report without independent inquiry or specifying basis for 15 crore figure constituted mere suspicion, insufficient for valid reopening. Assessment reopening was quashed in favor of assessee. en-us Tue, 30 Jan 2024 00:00:00 +0530 Fri, 02 Feb 2024 07:51:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448957 ITAT Delhi held that reopening of assessment under section 148 was invalid due to lack of proper application of mind by AO. Despite receiving information from DDIT(Inv.) about unexplained investment of over 15 crores in house property construction, AO failed to establish live link between materials and belief that income escaped assessment. Court noted factual inconsistencies in recorded reasons, including erroneous premise that assessee had not filed return when return was actually filed. AO's reliance solely on investigation report without independent inquiry or specifying basis for 15 crore figure constituted mere suspicion, insufficient for valid reopening. Assessment reopening was quashed in favor of assessee. Case-Laws Income Tax Tue, 30 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448957