https://www.taxtmi.com/caselaws?id=768424 Delhi HC held that reassessment under Section 147 cannot be sustained when the original reasons for reopening are not upheld. The AO had denied deductions under Sections 54 and 54EC, but ITAT allowed both deductions following established precedents. ITAT ruled that Section 54 permits investment in multiple residential houses and Section 54EC deduction can exceed Rs. 50 lakh. Since Revenue accepted ITAT's decision without appeal, the foundational reasons for reassessment failed. HC emphasized that AO cannot make roving inquiries beyond the recorded reasons for reopening assessment proceedings. The question of law was decided in favor of the assessee. en-us Tue, 25 Mar 2025 00:00:00 +0530 Mon, 07 Apr 2025 08:32:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768424 Delhi HC held that reassessment under Section 147 cannot be sustained when the original reasons for reopening are not upheld. The AO had denied deductions under Sections 54 and 54EC, but ITAT allowed both deductions following established precedents. ITAT ruled that Section 54 permits investment in multiple residential houses and Section 54EC deduction can exceed Rs. 50 lakh. Since Revenue accepted ITAT's decision without appeal, the foundational reasons for reassessment failed. HC emphasized that AO cannot make roving inquiries beyond the recorded reasons for reopening assessment proceedings. The question of law was decided in favor of the assessee. Case-Laws Income Tax Tue, 25 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768424