https://www.taxtmi.com/caselaws?id=767538 The ITAT Mumbai held that reopening of assessment was invalid and barred by limitation. The AO failed to record mandatory reasons before issuing notice under section 148, which is a prerequisite for assuming jurisdiction under section 147. The officer who issued the section 148 notice was different from the one who recorded reasons, and the revenue failed to prove otherwise. Additionally, reasons were recorded post 31/03/2021, beyond the six-year limitation period. The tribunal rejected the department's argument that recording reasons was unnecessary when no return was filed, ruling in favor of the assessee. en-us Fri, 28 Feb 2025 00:00:00 +0530 Thu, 20 Mar 2025 08:21:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767538 The ITAT Mumbai held that reopening of assessment was invalid and barred by limitation. The AO failed to record mandatory reasons before issuing notice under section 148, which is a prerequisite for assuming jurisdiction under section 147. The officer who issued the section 148 notice was different from the one who recorded reasons, and the revenue failed to prove otherwise. Additionally, reasons were recorded post 31/03/2021, beyond the six-year limitation period. The tribunal rejected the department's argument that recording reasons was unnecessary when no return was filed, ruling in favor of the assessee. Case-Laws Income Tax Fri, 28 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767538