https://www.taxtmi.com/caselaws?id=762313 ITAT Mumbai held that reopening of assessment under section 147 was invalid due to multiple procedural defects. The AO failed to specify the quantum of escaped income, merely stating "more than Rs. 1 lakh," and incorrectly treated the case as first-time assessment despite prior assessment under section 143(3). Since reopening occurred after four years from the relevant assessment year without establishing the assessee's failure to disclose material facts, the reassessment was bad in law. The assessee's objection under Rule 27 was allowed, and Revenue's appeal was dismissed. en-us Fri, 25 Oct 2024 00:00:00 +0530 Thu, 28 Nov 2024 08:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762313 ITAT Mumbai held that reopening of assessment under section 147 was invalid due to multiple procedural defects. The AO failed to specify the quantum of escaped income, merely stating "more than Rs. 1 lakh," and incorrectly treated the case as first-time assessment despite prior assessment under section 143(3). Since reopening occurred after four years from the relevant assessment year without establishing the assessee's failure to disclose material facts, the reassessment was bad in law. The assessee's objection under Rule 27 was allowed, and Revenue's appeal was dismissed. Case-Laws Income Tax Fri, 25 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762313