https://www.taxtmi.com/caselaws?id=768366 ITAT Delhi quashed reopening of assessment under section 147 for alleged bogus LTCG transactions. The tribunal held that AO failed to establish "reason to believe" as required under section 147, merely acting on investigation wing information without substantive material. The reasons recorded lacked rational nexus between alleged entry operators and the assessee, relying only on vague references to broker statements. The tribunal emphasized that "reason to believe" differs from "reason to suspect" and cannot be based on imagination. Without establishing the assessee's involvement or nexus with entry providers, all transactions in the scrip cannot be stereotyped as sham. Additions under section 68 were struck down as unsustainable and without legal authority. en-us Wed, 02 Apr 2025 00:00:00 +0530 Sat, 05 Apr 2025 08:23:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768366 ITAT Delhi quashed reopening of assessment under section 147 for alleged bogus LTCG transactions. The tribunal held that AO failed to establish "reason to believe" as required under section 147, merely acting on investigation wing information without substantive material. The reasons recorded lacked rational nexus between alleged entry operators and the assessee, relying only on vague references to broker statements. The tribunal emphasized that "reason to believe" differs from "reason to suspect" and cannot be based on imagination. Without establishing the assessee's involvement or nexus with entry providers, all transactions in the scrip cannot be stereotyped as sham. Additions under section 68 were struck down as unsustainable and without legal authority. Case-Laws Income Tax Wed, 02 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768366