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    <title>2025 (1) TMI 374 - ITAT DELHI</title>
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    <description>The HC determined that the reopening of the tax assessment under Section 147 of the Income-tax Act, 1961, was invalid. The court found that the assessing officer failed to independently apply their mind, relying instead on the Investigation Wing&#039;s report without examining any supporting materials. The reasons recorded for reopening did not establish a live nexus between the information received and the belief that income had escaped assessment. Consequently, the court allowed the appeal, emphasizing the necessity for substantive and independently verified reasons for reopening assessments.</description>
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    <pubDate>Wed, 18 Dec 2024 00:00:00 +0530</pubDate>
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      <title>2025 (1) TMI 374 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=764312</link>
      <description>The HC determined that the reopening of the tax assessment under Section 147 of the Income-tax Act, 1961, was invalid. The court found that the assessing officer failed to independently apply their mind, relying instead on the Investigation Wing&#039;s report without examining any supporting materials. The reasons recorded for reopening did not establish a live nexus between the information received and the belief that income had escaped assessment. Consequently, the court allowed the appeal, emphasizing the necessity for substantive and independently verified reasons for reopening assessments.</description>
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      <pubDate>Wed, 18 Dec 2024 00:00:00 +0530</pubDate>
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