https://www.taxtmi.com/caselaws?id=767071 The ITAT Delhi ruled in favor of the assessee, quashing the reopening of assessment under sections 147/148. The AO failed to apply independent mind while reopening, merely relying on information from Directorate of Income-tax (Systems) and Investigation Wing report from search operations in another group's case. The tribunal found the AO incorrectly claimed complete non-reporting of transactions that were already included in the assessee's computation. Since reopening was based on search and seizure operations in a third party's case, section 153C provisions should have applied instead of sections 147/148. The jurisdictional challenge was sustained. en-us Fri, 07 Mar 2025 00:00:00 +0530 Mon, 10 Mar 2025 08:42:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767071 The ITAT Delhi ruled in favor of the assessee, quashing the reopening of assessment under sections 147/148. The AO failed to apply independent mind while reopening, merely relying on information from Directorate of Income-tax (Systems) and Investigation Wing report from search operations in another group's case. The tribunal found the AO incorrectly claimed complete non-reporting of transactions that were already included in the assessee's computation. Since reopening was based on search and seizure operations in a third party's case, section 153C provisions should have applied instead of sections 147/148. The jurisdictional challenge was sustained. Case-Laws Income Tax Fri, 07 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767071