https://www.taxtmi.com/caselaws?id=758618 The ITAT Chennai set aside reassessment proceedings initiated under section 147, ruling that the AO lacked new tangible material or fresh information required for valid reopening. The reassessment was based on unreconciled NOSTRO account entries, agricultural debt relief amounts, and investment amortization claims already disclosed in annual accounts and income tax returns. Following Supreme Court precedent in Kelvinator case, the tribunal held that reassessment without fresh material renders proceedings null and void. The revenue's failure to raise these issues in prior section 263 proceedings further supported quashing the reassessment. Decision favored the assessee. en-us Thu, 29 Aug 2024 00:00:00 +0530 Mon, 16 Sep 2024 15:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=758618 The ITAT Chennai set aside reassessment proceedings initiated under section 147, ruling that the AO lacked new tangible material or fresh information required for valid reopening. The reassessment was based on unreconciled NOSTRO account entries, agricultural debt relief amounts, and investment amortization claims already disclosed in annual accounts and income tax returns. Following Supreme Court precedent in Kelvinator case, the tribunal held that reassessment without fresh material renders proceedings null and void. The revenue's failure to raise these issues in prior section 263 proceedings further supported quashing the reassessment. Decision favored the assessee. Case-Laws Income Tax Thu, 29 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=758618