https://www.taxtmi.com/caselaws?id=773796 The ITAT Delhi allowed the assessee's appeal challenging reassessment proceedings under Section 148. The court held that the Assessing Officer failed to record reasons prior to issuing the notice, violating legal provisions and showing non-application of mind. The Revenue sought to tax deemed rental income from properties allegedly belonging to the assessee, but failed to establish ownership despite the assessee's denial. The court emphasized that mere receipt of information does not constitute "reason to believe" that income escaped assessment, requiring prima facie inquiry and application of mind to available material before reopening proceedings. en-us Wed, 21 May 2025 00:00:00 +0530 Sat, 28 Jun 2025 08:31:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773796 The ITAT Delhi allowed the assessee's appeal challenging reassessment proceedings under Section 148. The court held that the Assessing Officer failed to record reasons prior to issuing the notice, violating legal provisions and showing non-application of mind. The Revenue sought to tax deemed rental income from properties allegedly belonging to the assessee, but failed to establish ownership despite the assessee's denial. The court emphasized that mere receipt of information does not constitute "reason to believe" that income escaped assessment, requiring prima facie inquiry and application of mind to available material before reopening proceedings. Case-Laws Income Tax Wed, 21 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773796