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    <title>2025 (4) TMI 1039 - ITAT DELHI</title>
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    <description>The ITAT Delhi held that reassessment proceedings initiated solely for verification of bank deposits were invalid, as the AO lacked tangible material to form a belief that income had escaped assessment. The tribunal distinguished between &#039;reason to believe&#039; and &#039;reason to suspect&#039;, finding the former was not satisfied. The revision proceedings under section 263 were also quashed as they were based on audit objections without proper foundation and denied natural justice. Both the reassessment order under sections 147/143(3) and the revision order under section 263 were set aside as being without jurisdiction. The assessee&#039;s appeal was allowed.</description>
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    <pubDate>Wed, 16 Apr 2025 00:00:00 +0530</pubDate>
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      <title>2025 (4) TMI 1039 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=769125</link>
      <description>The ITAT Delhi held that reassessment proceedings initiated solely for verification of bank deposits were invalid, as the AO lacked tangible material to form a belief that income had escaped assessment. The tribunal distinguished between &#039;reason to believe&#039; and &#039;reason to suspect&#039;, finding the former was not satisfied. The revision proceedings under section 263 were also quashed as they were based on audit objections without proper foundation and denied natural justice. Both the reassessment order under sections 147/143(3) and the revision order under section 263 were set aside as being without jurisdiction. The assessee&#039;s appeal was allowed.</description>
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