https://www.taxtmi.com/caselaws?id=449277 ITAT Ahmedabad held that reassessment proceedings u/s 147 were invalid due to lack of year-specific belief of income escapement. The AO relied on consolidated CBI report covering multiple years without independent application of mind, constituting impermissible "borrowed belief." Reasons recorded were vague and failed to specify escapement for each assessment year. The tribunal emphasized that reassessment requires tangible material with live nexus to alleged escaped income for specific years, not consolidated information. Since assessments were invalid, penalty u/s 271(1)(c) was also quashed. Appeal decided in favor of assessee. en-us Mon, 05 Feb 2024 00:00:00 +0530 Thu, 08 Feb 2024 16:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449277 ITAT Ahmedabad held that reassessment proceedings u/s 147 were invalid due to lack of year-specific belief of income escapement. The AO relied on consolidated CBI report covering multiple years without independent application of mind, constituting impermissible "borrowed belief." Reasons recorded were vague and failed to specify escapement for each assessment year. The tribunal emphasized that reassessment requires tangible material with live nexus to alleged escaped income for specific years, not consolidated information. Since assessments were invalid, penalty u/s 271(1)(c) was also quashed. Appeal decided in favor of assessee. Case-Laws Income Tax Mon, 05 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449277