https://www.taxtmi.com/caselaws?id=764119 ITAT Delhi held that reassessment proceedings under section 147 were invalid due to borrowed satisfaction and mechanical recording of reasons by the AO without verifying information from Investigation Wing. The tribunal found reassessment was based on change of opinion rather than valid grounds. Following binding precedent from Delhi HC in ATS Infrastructure Ltd., the tribunal quashed the reassessment orders as bad in law, ruling in favor of the assessee. en-us Tue, 31 Dec 2024 00:00:00 +0530 Thu, 02 Jan 2025 18:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764119 ITAT Delhi held that reassessment proceedings under section 147 were invalid due to borrowed satisfaction and mechanical recording of reasons by the AO without verifying information from Investigation Wing. The tribunal found reassessment was based on change of opinion rather than valid grounds. Following binding precedent from Delhi HC in ATS Infrastructure Ltd., the tribunal quashed the reassessment orders as bad in law, ruling in favor of the assessee. Case-Laws Income Tax Tue, 31 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764119