https://www.taxtmi.com/caselaws?id=450955 HC held that reopening under s.147 was invalid because the reasons to believe were founded on fundamentally incorrect facts pertaining to a different entity; the assessee had filed and been assessed on its return, and dates and four-year limitations were misstated. The AO failed to correct or address these factual errors in the objections order, demonstrating non-application of mind and warranting an adverse inference against Revenue. Consequently the AO lacked jurisdiction to reopen, and the challenge succeeded in favour of the assessee. en-us Mon, 11 Mar 2024 00:00:00 +0530 Fri, 19 Sep 2025 15:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450955 HC held that reopening under s.147 was invalid because the reasons to believe were founded on fundamentally incorrect facts pertaining to a different entity; the assessee had filed and been assessed on its return, and dates and four-year limitations were misstated. The AO failed to correct or address these factual errors in the objections order, demonstrating non-application of mind and warranting an adverse inference against Revenue. Consequently the AO lacked jurisdiction to reopen, and the challenge succeeded in favour of the assessee. Case-Laws Income Tax Mon, 11 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450955