https://www.taxtmi.com/caselaws?id=765003 The Bombay HC quashed reassessment proceedings under Section 147, ruling that jurisdictional conditions under the first proviso were not satisfied. The court found that reasons for reopening were based on information already available during regular assessment proceedings, indicating the predecessor officer's incorrect assessment rather than new material. The AO failed to rebut petitioner's jurisdictional objections, merely reproducing judgments without addressing specific concerns. The court rejected reliance on audit objections as they were not mentioned in recorded reasons. The notices under Section 148 were declared wholly without jurisdiction, illegal, arbitrary and liable to be quashed. en-us Mon, 20 Jan 2025 00:00:00 +0530 Mon, 03 Mar 2025 12:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=765003 The Bombay HC quashed reassessment proceedings under Section 147, ruling that jurisdictional conditions under the first proviso were not satisfied. The court found that reasons for reopening were based on information already available during regular assessment proceedings, indicating the predecessor officer's incorrect assessment rather than new material. The AO failed to rebut petitioner's jurisdictional objections, merely reproducing judgments without addressing specific concerns. The court rejected reliance on audit objections as they were not mentioned in recorded reasons. The notices under Section 148 were declared wholly without jurisdiction, illegal, arbitrary and liable to be quashed. Case-Laws Income Tax Mon, 20 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=765003