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    <title>2025 (5) TMI 34 - DELHI HIGH COURT</title>
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    <description>Delhi HC allowed the assessee&#039;s appeal against reopening of assessment u/s 147. The AO had recorded reasons based on investigation wing information alleging the assessee was a beneficiary claiming bogus LTCG through fabricated contract notes and penny scrip manipulation. However, the court held that the AO failed to disclose material facts from the investigation report that would indicate the assessee&#039;s involvement in the alleged manipulation. Since the recorded reasons were silent on basic facts necessary to form even a prima facie opinion, the reassessment action was unsustainable.</description>
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    <pubDate>Mon, 10 Mar 2025 00:00:00 +0530</pubDate>
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      <title>2025 (5) TMI 34 - DELHI HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=769762</link>
      <description>Delhi HC allowed the assessee&#039;s appeal against reopening of assessment u/s 147. The AO had recorded reasons based on investigation wing information alleging the assessee was a beneficiary claiming bogus LTCG through fabricated contract notes and penny scrip manipulation. However, the court held that the AO failed to disclose material facts from the investigation report that would indicate the assessee&#039;s involvement in the alleged manipulation. Since the recorded reasons were silent on basic facts necessary to form even a prima facie opinion, the reassessment action was unsustainable.</description>
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      <pubDate>Mon, 10 Mar 2025 00:00:00 +0530</pubDate>
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