https://www.taxtmi.com/caselaws?id=766906 ITAT Delhi held that reassessment proceedings under section 147 were invalid due to mechanical recording of reasons by the AO without independent application of mind or proper verification. The AO failed to provide transaction details for alleged accommodation entries involving long-term capital gains from penny stocks. The reasons recorded were found incomplete and vague, making the section 148 notice bad in law. Consequently, the reassessment order under sections 144/144B was declared invalid. Since revisionary proceedings under section 263 by Pr. CIT originated from an invalid reassessment order, the ITAT quashed the revisionary order, following precedent from Westlife Development Ltd. The additional grounds of appeal were allowed. en-us Thu, 27 Feb 2025 00:00:00 +0530 Thu, 06 Mar 2025 07:35:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=766906 ITAT Delhi held that reassessment proceedings under section 147 were invalid due to mechanical recording of reasons by the AO without independent application of mind or proper verification. The AO failed to provide transaction details for alleged accommodation entries involving long-term capital gains from penny stocks. The reasons recorded were found incomplete and vague, making the section 148 notice bad in law. Consequently, the reassessment order under sections 144/144B was declared invalid. Since revisionary proceedings under section 263 by Pr. CIT originated from an invalid reassessment order, the ITAT quashed the revisionary order, following precedent from Westlife Development Ltd. The additional grounds of appeal were allowed. Case-Laws Income Tax Thu, 27 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=766906