https://www.taxtmi.com/caselaws?id=773281 The ITAT Rajkot quashed reassessment proceedings initiated under Section 147 of the Income Tax Act, finding multiple procedural defects. The assessing officer failed to properly follow Section 148A procedures and created contradictions between allegations of unaccounted receipts from property sales and justifications for reopening beyond normal time limits. The notice incorrectly stated reopening was due to search in assessee's case when search was conducted on a third party. The authority failed to demonstrate escaped income of Rs. 50 lakh or more as required under Section 149(1)(b) for extended limitation period. The proceedings were deemed wholly invalid due to these incurable defects. en-us Tue, 10 Jun 2025 00:00:00 +0530 Fri, 20 Jun 2025 08:34:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773281 The ITAT Rajkot quashed reassessment proceedings initiated under Section 147 of the Income Tax Act, finding multiple procedural defects. The assessing officer failed to properly follow Section 148A procedures and created contradictions between allegations of unaccounted receipts from property sales and justifications for reopening beyond normal time limits. The notice incorrectly stated reopening was due to search in assessee's case when search was conducted on a third party. The authority failed to demonstrate escaped income of Rs. 50 lakh or more as required under Section 149(1)(b) for extended limitation period. The proceedings were deemed wholly invalid due to these incurable defects. Case-Laws Income Tax Tue, 10 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773281