https://www.taxtmi.com/caselaws?id=773592 ITAT Delhi held that reopening proceedings under section 147/148 cannot be initiated while proceedings under section 154 are pending. The assessee received two notices regarding TDS non-deduction on lease rent and alleged non-accounting of short-term capital gain. Following SC precedent in S.M. Overseas case, the Tribunal concluded that Revenue cannot simultaneously pursue both proceedings. Since the AO was already aware of the disputed transactions through rectification proceedings, subsequent assumption of jurisdiction under section 147 constituted reopening on stale information and mere change of opinion, which is impermissible. en-us Wed, 18 Jun 2025 00:00:00 +0530 Wed, 25 Jun 2025 09:23:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773592 ITAT Delhi held that reopening proceedings under section 147/148 cannot be initiated while proceedings under section 154 are pending. The assessee received two notices regarding TDS non-deduction on lease rent and alleged non-accounting of short-term capital gain. Following SC precedent in S.M. Overseas case, the Tribunal concluded that Revenue cannot simultaneously pursue both proceedings. Since the AO was already aware of the disputed transactions through rectification proceedings, subsequent assumption of jurisdiction under section 147 constituted reopening on stale information and mere change of opinion, which is impermissible. Case-Laws Income Tax Wed, 18 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773592