https://www.taxtmi.com/caselaws?id=313350 ITAT Delhi quashed reassessment proceedings under section 147 after finding that the AO's reasons to believe were based on factually incorrect assumptions. The AO incorrectly assumed the assessee was a non-PAN case despite having PAN and regularly filing returns, and wrongly believed no return was filed for AY 2009-10 when it was actually filed on 22.09.2010. Since the foundation for reopening was based on incorrect facts, the entire reassessment was invalidated. The tribunal followed precedents from Mumbai ITAT and HC decisions, ruling in favor of the assessee and quashing the proceedings. en-us Fri, 12 Jan 2024 00:00:00 +0530 Mon, 08 Apr 2024 19:06:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=313350 ITAT Delhi quashed reassessment proceedings under section 147 after finding that the AO's reasons to believe were based on factually incorrect assumptions. The AO incorrectly assumed the assessee was a non-PAN case despite having PAN and regularly filing returns, and wrongly believed no return was filed for AY 2009-10 when it was actually filed on 22.09.2010. Since the foundation for reopening was based on incorrect facts, the entire reassessment was invalidated. The tribunal followed precedents from Mumbai ITAT and HC decisions, ruling in favor of the assessee and quashing the proceedings. Case-Laws Income Tax Fri, 12 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=313350