https://www.taxtmi.com/caselaws?id=449379 The ITAT Delhi held that reopening an assessment u/s 147 beyond the four-year limitation period was invalid when based on the same entities and reasons previously examined. The assessee received share applications from five entities that were already scrutinized in 2013 and accepted in the 2014 assessment order u/s 147/143(3). The Assessing Officer attempted reopening in 2017 using identical reasons without any new material or information. The tribunal ruled that reopening the same case twice for amounts from identical entities, absent fresh evidence, was bad in law and rendered the assessment order void ab initio, deciding in favor of the assessee. en-us Tue, 06 Feb 2024 00:00:00 +0530 Sat, 10 Feb 2024 07:44:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449379 The ITAT Delhi held that reopening an assessment u/s 147 beyond the four-year limitation period was invalid when based on the same entities and reasons previously examined. The assessee received share applications from five entities that were already scrutinized in 2013 and accepted in the 2014 assessment order u/s 147/143(3). The Assessing Officer attempted reopening in 2017 using identical reasons without any new material or information. The tribunal ruled that reopening the same case twice for amounts from identical entities, absent fresh evidence, was bad in law and rendered the assessment order void ab initio, deciding in favor of the assessee. Case-Laws Income Tax Tue, 06 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449379