https://www.taxtmi.com/caselaws?id=765056 ITAT Delhi dismissed Revenue's appeal challenging CIT(A)'s order quashing reassessment u/s 147 regarding unexplained share application money credits u/s 68. AO reopened assessment after four years based on information about accommodation entries from another company. However, AO failed to record reasons showing assessee's failure to disclose material facts, as required u/s 147(1). Original assessment u/s 143(3) had already accepted the transaction after verification. ITAT held reopening was merely change of opinion without jurisdiction, upholding CIT(A)'s decision to quash reassessment proceedings. en-us Wed, 22 Jan 2025 00:00:00 +0530 Fri, 24 Jan 2025 08:44:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=765056 ITAT Delhi dismissed Revenue's appeal challenging CIT(A)'s order quashing reassessment u/s 147 regarding unexplained share application money credits u/s 68. AO reopened assessment after four years based on information about accommodation entries from another company. However, AO failed to record reasons showing assessee's failure to disclose material facts, as required u/s 147(1). Original assessment u/s 143(3) had already accepted the transaction after verification. ITAT held reopening was merely change of opinion without jurisdiction, upholding CIT(A)'s decision to quash reassessment proceedings. Case-Laws Income Tax Wed, 22 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=765056