https://www.taxtmi.com/caselaws?id=456980 The ITAT Delhi quashed the reassessment proceedings initiated under Section 147/148 for lack of valid jurisdiction. The tribunal held that the AO's reasons to believe were based on generic allegations from investigation wings regarding accommodation entries and fictitious profits without specific material evidence. The reasons recorded failed to establish a live link between the information received and the belief formed regarding income escapement. The tribunal found the objections were disposed of summarily without proper consideration, and the Pr. CIT's approval under Section 151 was granted without adequate application of mind to the deficiencies in the approval memo. The reassessment was declared bad in law and quashed in favor of the assessee. en-us Mon, 07 Aug 2023 00:00:00 +0530 Mon, 08 Jun 2026 14:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=456980 The ITAT Delhi quashed the reassessment proceedings initiated under Section 147/148 for lack of valid jurisdiction. The tribunal held that the AO's reasons to believe were based on generic allegations from investigation wings regarding accommodation entries and fictitious profits without specific material evidence. The reasons recorded failed to establish a live link between the information received and the belief formed regarding income escapement. The tribunal found the objections were disposed of summarily without proper consideration, and the Pr. CIT's approval under Section 151 was granted without adequate application of mind to the deficiencies in the approval memo. The reassessment was declared bad in law and quashed in favor of the assessee. Case-Laws Income Tax Mon, 07 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=456980