https://www.taxtmi.com/caselaws?id=764802 The ITAT Delhi ruled in favor of the assessee challenging the validity of assessment reopening. The tribunal found that the AO failed to obtain valid approval under Section 151 from the prescribed authority, with no evidence of proper application of mind by the competent authority. Additionally, the reopening reasons were not based on tangible material, as the AO initially cited accommodation entries from five entities but only one entity was actually involved. The tribunal held that reopening reasons cannot be modified after recording and must satisfy statutory conditions from the outset. en-us Wed, 15 Jan 2025 00:00:00 +0530 Fri, 17 Jan 2025 18:46:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764802 The ITAT Delhi ruled in favor of the assessee challenging the validity of assessment reopening. The tribunal found that the AO failed to obtain valid approval under Section 151 from the prescribed authority, with no evidence of proper application of mind by the competent authority. Additionally, the reopening reasons were not based on tangible material, as the AO initially cited accommodation entries from five entities but only one entity was actually involved. The tribunal held that reopening reasons cannot be modified after recording and must satisfy statutory conditions from the outset. Case-Laws Income Tax Wed, 15 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764802