https://www.taxtmi.com/caselaws?id=450953 The Bombay HC held that reopening of assessment after four years was invalid due to incorrect facts and non-application of mind by the AO. The AO erroneously recorded cash deposits of Rs. 3,73,72,707/- when HDFC Bank certified only Rs. 1,87,39,187/- was deposited in cash during FY 2012-13. The confusion arose from partnership firm conversion to private limited company with different PANs, causing bank to quote wrong PAN in AIR Report. The AO failed to examine that the alleged separate deposit of Rs. 1,86,33,520/- was actually part of the certified amount, not additional. Without proper application of mind and based on incorrect facts, the reassessment proceedings were declared null and void. Decision favored assessee. en-us Mon, 11 Mar 2024 00:00:00 +0530 Wed, 09 Jul 2025 16:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450953 The Bombay HC held that reopening of assessment after four years was invalid due to incorrect facts and non-application of mind by the AO. The AO erroneously recorded cash deposits of Rs. 3,73,72,707/- when HDFC Bank certified only Rs. 1,87,39,187/- was deposited in cash during FY 2012-13. The confusion arose from partnership firm conversion to private limited company with different PANs, causing bank to quote wrong PAN in AIR Report. The AO failed to examine that the alleged separate deposit of Rs. 1,86,33,520/- was actually part of the certified amount, not additional. Without proper application of mind and based on incorrect facts, the reassessment proceedings were declared null and void. Decision favored assessee. Case-Laws Income Tax Mon, 11 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450953