https://www.taxtmi.com/caselaws?id=462650 The ITAT Mumbai quashed the reassessment under section 147 due to multiple procedural and factual deficiencies. The AO incorrectly assumed the assessee had not filed a return, when records showed a return was filed and assessment completed under section 143(3). The notice under section 148 was issued beyond four years without establishing the assessee's failure to disclose material facts as required by the proviso to section 147. The AO failed to dispose of the assessee's objections through a separate speaking order and provided vague reasons without specifically naming the assessee. The tribunal held the AO invalidly assumed jurisdiction for reopening. en-us Fri, 23 Dec 2022 00:00:00 +0530 Mon, 07 Jul 2025 18:29:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462650 The ITAT Mumbai quashed the reassessment under section 147 due to multiple procedural and factual deficiencies. The AO incorrectly assumed the assessee had not filed a return, when records showed a return was filed and assessment completed under section 143(3). The notice under section 148 was issued beyond four years without establishing the assessee's failure to disclose material facts as required by the proviso to section 147. The AO failed to dispose of the assessee's objections through a separate speaking order and provided vague reasons without specifically naming the assessee. The tribunal held the AO invalidly assumed jurisdiction for reopening. Case-Laws Income Tax Fri, 23 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462650