https://www.taxtmi.com/caselaws?id=774671 ITAT, Delhi (AT) held the reopening under s.147 invalid, finding the AO acted on borrowed satisfaction from an undisclosed Investigation Wing report and handwritten papers without any independent enquiry. The approval under s.151 was quashed as mechanically granted and factually erroneous (assessment already completed u/s 143(3) despite form stating otherwise). Given these infirmities, the grounds for reopening failed and the assessee's appeal was allowed, dismissing the revenue's reopening. en-us Fri, 30 May 2025 00:00:00 +0530 Tue, 14 Oct 2025 11:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774671 ITAT, Delhi (AT) held the reopening under s.147 invalid, finding the AO acted on borrowed satisfaction from an undisclosed Investigation Wing report and handwritten papers without any independent enquiry. The approval under s.151 was quashed as mechanically granted and factually erroneous (assessment already completed u/s 143(3) despite form stating otherwise). Given these infirmities, the grounds for reopening failed and the assessee's appeal was allowed, dismissing the revenue's reopening. Case-Laws Income Tax Fri, 30 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774671