https://www.taxtmi.com/caselaws?id=753469 Delhi HC ruled against the Revenue in reassessment proceedings initiated after four years. The court held that the AO lacked valid "reasons to believe" under Section 147, as the satisfaction note vaguely referred to "perusal of records" without disclosing specific circumstances triggering reassessment. The court found no live link between recorded reasons and belief formation. Crucially, the Revenue possessed no fresh tangible material, which is mandatory for reassessment beyond the four-year statutory period. The CIT(A)'s reliance on subsequent Section 201 proceedings was deemed perverse since those proceedings commenced after the reassessment notice was issued, making alleged non-disclosure irrelevant to the original satisfaction. The reassessment proceedings were held invalid. en-us Thu, 30 May 2024 00:00:00 +0530 Sat, 01 Jun 2024 11:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=753469 Delhi HC ruled against the Revenue in reassessment proceedings initiated after four years. The court held that the AO lacked valid "reasons to believe" under Section 147, as the satisfaction note vaguely referred to "perusal of records" without disclosing specific circumstances triggering reassessment. The court found no live link between recorded reasons and belief formation. Crucially, the Revenue possessed no fresh tangible material, which is mandatory for reassessment beyond the four-year statutory period. The CIT(A)'s reliance on subsequent Section 201 proceedings was deemed perverse since those proceedings commenced after the reassessment notice was issued, making alleged non-disclosure irrelevant to the original satisfaction. The reassessment proceedings were held invalid. Case-Laws Income Tax Thu, 30 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=753469