https://www.taxtmi.com/caselaws?id=765228 The ITAT Delhi quashed the reopening of assessment under section 147 for AY 2016-17. The AO's belief that the assessee had not filed a return of income was factually incorrect, as the return was filed on 02.08.2016 declaring income of INR 6,40,160. The tribunal held that reasons recorded contrary to facts vitiate the foundation for reopening. Additionally, the sanction under section 151 was found to be a mere formality without speaking approval, rendering the section 148 notice and subsequent assessment invalid. en-us Fri, 24 Jan 2025 00:00:00 +0530 Tue, 28 Jan 2025 08:24:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=765228 The ITAT Delhi quashed the reopening of assessment under section 147 for AY 2016-17. The AO's belief that the assessee had not filed a return of income was factually incorrect, as the return was filed on 02.08.2016 declaring income of INR 6,40,160. The tribunal held that reasons recorded contrary to facts vitiate the foundation for reopening. Additionally, the sanction under section 151 was found to be a mere formality without speaking approval, rendering the section 148 notice and subsequent assessment invalid. Case-Laws Income Tax Fri, 24 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=765228