https://www.taxtmi.com/caselaws?id=460287 The ITAT AGRA quashed reassessment proceedings u/s 147 for assessment year 2012-13, ruling the assumption of jurisdiction invalid and void ab initio. The AO lacked information to form belief that income escaped assessment when recording reasons and issuing notice u/s 148, obtaining relevant documents from Investigation Wing only during reassessment proceedings. Additionally, the AO's final reassessment order differed from recorded reasons - while reasons cited accommodation entries of Rs 5 lakhs, the final order made additions for estimated gross profit instead. Following Ranbaxy Laboratories precedent, the tribunal held the reopening invalid due to absence of valid belief formation and material change between reasons and final assessment. Decision favored the assessee. en-us Thu, 21 Nov 2024 00:00:00 +0530 Fri, 17 Jan 2025 20:05:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460287 The ITAT AGRA quashed reassessment proceedings u/s 147 for assessment year 2012-13, ruling the assumption of jurisdiction invalid and void ab initio. The AO lacked information to form belief that income escaped assessment when recording reasons and issuing notice u/s 148, obtaining relevant documents from Investigation Wing only during reassessment proceedings. Additionally, the AO's final reassessment order differed from recorded reasons - while reasons cited accommodation entries of Rs 5 lakhs, the final order made additions for estimated gross profit instead. Following Ranbaxy Laboratories precedent, the tribunal held the reopening invalid due to absence of valid belief formation and material change between reasons and final assessment. Decision favored the assessee. Case-Laws Income Tax Thu, 21 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460287