https://www.taxtmi.com/caselaws?id=764538 Delhi HC held that reassessment proceedings under Section 147 were invalid where the AO lacked material evidence to support allegations of accommodation entries. While the court found that issuing notice under Section 148A(b) to an amalgamated entity was not fatal when proceedings continued in the successor's name, the fundamental premise for reopening assessment failed. The AO must have reasonable certainty that alleged entries exist before initiating reassessment, not merely rely on contested information without examining underlying material. The notices under Sections 148 and 148A were set aside. en-us Fri, 10 Jan 2025 00:00:00 +0530 Mon, 13 Jan 2025 08:39:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764538 Delhi HC held that reassessment proceedings under Section 147 were invalid where the AO lacked material evidence to support allegations of accommodation entries. While the court found that issuing notice under Section 148A(b) to an amalgamated entity was not fatal when proceedings continued in the successor's name, the fundamental premise for reopening assessment failed. The AO must have reasonable certainty that alleged entries exist before initiating reassessment, not merely rely on contested information without examining underlying material. The notices under Sections 148 and 148A were set aside. Case-Laws Income Tax Fri, 10 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764538