https://www.taxtmi.com/caselaws?id=457600 ITAT Delhi held that reopening of assessment under section 147 was invalid where AO relied solely on Investigation Wing observations without independent application of mind. The AO failed to establish live link between investigation report and reasons to believe tax escaped assessment for the specific year. Merely doubting assessee's involvement in accommodation entries without proof, examination of returns, or independent verification was insufficient. The tribunal found no independent enquiry conducted by AO to conclude tax evasion occurred. Following Delhi HC precedents, proceedings under section 148 were declared void ab initio and quashed in assessee's favor. en-us Fri, 20 May 2022 00:00:00 +0530 Thu, 26 Sep 2024 18:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=457600 ITAT Delhi held that reopening of assessment under section 147 was invalid where AO relied solely on Investigation Wing observations without independent application of mind. The AO failed to establish live link between investigation report and reasons to believe tax escaped assessment for the specific year. Merely doubting assessee's involvement in accommodation entries without proof, examination of returns, or independent verification was insufficient. The tribunal found no independent enquiry conducted by AO to conclude tax evasion occurred. Following Delhi HC precedents, proceedings under section 148 were declared void ab initio and quashed in assessee's favor. Case-Laws Income Tax Fri, 20 May 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=457600