https://www.taxtmi.com/caselaws?id=462468 The HC quashed reassessment proceedings under Section 148A for non-application of mind by the AO. The AO failed to distinguish between sale and purchase transactions, relied on GST department information without considering its relevance to income tax, and did not provide material relied upon despite petitioner's request. The Court held that AO must have prima facie grounds for reopening assessment and cannot conduct fishing enquiries. The AO ignored petitioner's documentary evidence including invoices, transportation documents, and banking records substantiating legitimate sales transactions. The mandatory procedure under Section 148A was not properly followed, vitiating the proceedings as unreasonable exercise of power. en-us Wed, 19 Mar 2025 00:00:00 +0530 Tue, 24 Jun 2025 22:02:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462468 The HC quashed reassessment proceedings under Section 148A for non-application of mind by the AO. The AO failed to distinguish between sale and purchase transactions, relied on GST department information without considering its relevance to income tax, and did not provide material relied upon despite petitioner's request. The Court held that AO must have prima facie grounds for reopening assessment and cannot conduct fishing enquiries. The AO ignored petitioner's documentary evidence including invoices, transportation documents, and banking records substantiating legitimate sales transactions. The mandatory procedure under Section 148A was not properly followed, vitiating the proceedings as unreasonable exercise of power. Case-Laws Income Tax Wed, 19 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462468