https://www.taxtmi.com/caselaws?id=762617 ITAT Mumbai held that reassessment proceedings initiated under section 147 based solely on internal audit objection were invalid. The tribunal determined that internal audit memo dated 06.02.2018 did not qualify as "information" under Explanation 1 to section 148 on the date of show cause notice issuance (29.06.2021). Following Bombay HC precedent in Hashmukh Estates case, ITAT ruled that reassessment notice based on internal audit objection was impermissible in law. The tribunal rejected Revenue's argument regarding amended provisions effective 01.04.2022, confirming CIT(A)'s decision to quash proceedings. Notice under section 148 was declared void ab initio. Assessee's appeal was allowed. en-us Fri, 29 Nov 2024 00:00:00 +0530 Tue, 03 Dec 2024 12:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762617 ITAT Mumbai held that reassessment proceedings initiated under section 147 based solely on internal audit objection were invalid. The tribunal determined that internal audit memo dated 06.02.2018 did not qualify as "information" under Explanation 1 to section 148 on the date of show cause notice issuance (29.06.2021). Following Bombay HC precedent in Hashmukh Estates case, ITAT ruled that reassessment notice based on internal audit objection was impermissible in law. The tribunal rejected Revenue's argument regarding amended provisions effective 01.04.2022, confirming CIT(A)'s decision to quash proceedings. Notice under section 148 was declared void ab initio. Assessee's appeal was allowed. Case-Laws Income Tax Fri, 29 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762617