https://www.taxtmi.com/caselaws?id=449390 The ITAT Delhi held that the reopening of assessment under section 148 was invalid due to mechanical approval by the Pr. CIT. The tribunal found factual mistakes in recorded reasons, lack of independent application of mind by the AO, and contradictions with earlier submissions before the Settlement Commission. The AO's belief regarding illegal gratification from a contractor was deemed wrong as there was no tangible material to support income escapement. The case involved unexplained cash credit allegations, but the assessee provided rent agreement evidence. The tribunal concluded the approval under section 151 was mechanical, making the AO's jurisdiction assumption legally invalid. Decision favored the assessee. en-us Thu, 08 Feb 2024 00:00:00 +0530 Sat, 10 Feb 2024 07:45:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449390 The ITAT Delhi held that the reopening of assessment under section 148 was invalid due to mechanical approval by the Pr. CIT. The tribunal found factual mistakes in recorded reasons, lack of independent application of mind by the AO, and contradictions with earlier submissions before the Settlement Commission. The AO's belief regarding illegal gratification from a contractor was deemed wrong as there was no tangible material to support income escapement. The case involved unexplained cash credit allegations, but the assessee provided rent agreement evidence. The tribunal concluded the approval under section 151 was mechanical, making the AO's jurisdiction assumption legally invalid. Decision favored the assessee. Case-Laws Income Tax Thu, 08 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449390