https://www.taxtmi.com/caselaws?id=757040 ITAT Amritsar held that reopening of assessment u/s 147 was invalid where AO failed to record that assessee had filed original return. The reopening was initiated based on survey operation at hotel owned by HUF karta's wife. Court found that without mentioning assessee's return filing status in recorded reasons, AO could not establish reason to believe income escaped assessment due to non-disclosure of material facts. The assumption of jurisdiction u/s 148 was therefore invalid due to wrong recorded facts. Decision favored assessee. en-us Mon, 01 Jul 2024 00:00:00 +0530 Tue, 13 Aug 2024 17:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=757040 ITAT Amritsar held that reopening of assessment u/s 147 was invalid where AO failed to record that assessee had filed original return. The reopening was initiated based on survey operation at hotel owned by HUF karta's wife. Court found that without mentioning assessee's return filing status in recorded reasons, AO could not establish reason to believe income escaped assessment due to non-disclosure of material facts. The assumption of jurisdiction u/s 148 was therefore invalid due to wrong recorded facts. Decision favored assessee. Case-Laws Income Tax Mon, 01 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=757040