https://www.taxtmi.com/caselaws?id=775619 The ITAT RAIPUR held that the reopening of assessment under sections 147 and 148 was invalid due to the absence of any failure by the assessee to disclose material facts as required by the first proviso to section 147. The reasons recorded by the AO were not supplied to the assessee despite requests, violating mandatory legal provisions and Supreme Court precedent in GKN Driveshaft. Consequently, the reassessment proceedings were held to be ultra vires and void ab initio. The impugned assessment order dated 19.03.2022 was quashed, and the appeal of the assessee was allowed. en-us Thu, 24 Jul 2025 00:00:00 +0530 Mon, 28 Jul 2025 08:27:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775619 The ITAT RAIPUR held that the reopening of assessment under sections 147 and 148 was invalid due to the absence of any failure by the assessee to disclose material facts as required by the first proviso to section 147. The reasons recorded by the AO were not supplied to the assessee despite requests, violating mandatory legal provisions and Supreme Court precedent in GKN Driveshaft. Consequently, the reassessment proceedings were held to be ultra vires and void ab initio. The impugned assessment order dated 19.03.2022 was quashed, and the appeal of the assessee was allowed. Case-Laws Income Tax Thu, 24 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775619