https://www.taxtmi.com/caselaws?id=752956 The ITAT Indore quashed a reassessment order passed under section 147 after finding the original reason for reopening was invalid. The revenue alleged the assessee had entered sham transactions with a shell company, but failed to prove any such transactions occurred. The ITAT held that once the foundational reason for reassessment becomes invalid, the entire proceeding becomes void. The court clarified that the third proviso to section 147 does not authorize the AO to assess independent income items when original reasons fail to survive, contrary to the AO's interpretation. The assessee's appeal succeeded. en-us Tue, 02 Jan 2024 00:00:00 +0530 Wed, 22 May 2024 06:56:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752956 The ITAT Indore quashed a reassessment order passed under section 147 after finding the original reason for reopening was invalid. The revenue alleged the assessee had entered sham transactions with a shell company, but failed to prove any such transactions occurred. The ITAT held that once the foundational reason for reassessment becomes invalid, the entire proceeding becomes void. The court clarified that the third proviso to section 147 does not authorize the AO to assess independent income items when original reasons fail to survive, contrary to the AO's interpretation. The assessee's appeal succeeded. Case-Laws Income Tax Tue, 02 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752956