https://www.taxtmi.com/caselaws?id=459053 ITAT Mumbai quashed the reassessment proceedings initiated by AO based on information from DDIT regarding unexplained share capital and premium under section 68. The tribunal found that AO failed to independently apply mind and merely reproduced DDIT's information without examining contradictory details about the assessee's relationship with a key person. AO could not establish how share capital constituted escaped income or demonstrate proper linkage between available material and belief formation. The reopening was held invalid due to non-application of mind and procedural defects. en-us Thu, 23 Nov 2023 00:00:00 +0530 Wed, 27 Nov 2024 18:34:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=459053 ITAT Mumbai quashed the reassessment proceedings initiated by AO based on information from DDIT regarding unexplained share capital and premium under section 68. The tribunal found that AO failed to independently apply mind and merely reproduced DDIT's information without examining contradictory details about the assessee's relationship with a key person. AO could not establish how share capital constituted escaped income or demonstrate proper linkage between available material and belief formation. The reopening was held invalid due to non-application of mind and procedural defects. Case-Laws Income Tax Thu, 23 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=459053