https://www.taxtmi.com/caselaws?id=755667 The ITAT Kolkata quashed reassessment proceedings initiated by the AO against a company that had filed returns under section 139(1) and processed under section 143(1)(a). The tribunal found two fatal flaws: first, the AO failed to dispose of objections raised by the assessee against the reopening; second, the reasons recorded for reopening were inadequate, being merely based on information from Investigation Wing constituting "reasons to suspect" rather than "reasons to believe" as required under section 147. The tribunal held that mere suspicion of income escapement is insufficient to justify reopening assessment, consequently quashing the section 148 notice and resulting reassessment order. en-us Mon, 08 Jul 2024 00:00:00 +0530 Wed, 17 Jul 2024 08:06:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755667 The ITAT Kolkata quashed reassessment proceedings initiated by the AO against a company that had filed returns under section 139(1) and processed under section 143(1)(a). The tribunal found two fatal flaws: first, the AO failed to dispose of objections raised by the assessee against the reopening; second, the reasons recorded for reopening were inadequate, being merely based on information from Investigation Wing constituting "reasons to suspect" rather than "reasons to believe" as required under section 147. The tribunal held that mere suspicion of income escapement is insufficient to justify reopening assessment, consequently quashing the section 148 notice and resulting reassessment order. Case-Laws Income Tax Mon, 08 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755667