https://www.taxtmi.com/caselaws?id=776172 The ITAT Delhi held that reopening assessment under section 147 requires a valid reason to believe, which was absent as the assessee had filed the return of income contrary to the department's claim. The belief based on incorrect facts violated the prerequisites of section 147, rendering the reopening notice under section 148 invalid. Following precedents, the tribunal found the reopening proceedings lacked jurisdiction and quashed the notice. Consequently, the appeal by the assessee was allowed without examining the merits of the additions. en-us Fri, 03 Jan 2025 00:00:00 +0530 Wed, 06 Aug 2025 08:19:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776172 The ITAT Delhi held that reopening assessment under section 147 requires a valid reason to believe, which was absent as the assessee had filed the return of income contrary to the department's claim. The belief based on incorrect facts violated the prerequisites of section 147, rendering the reopening notice under section 148 invalid. Following precedents, the tribunal found the reopening proceedings lacked jurisdiction and quashed the notice. Consequently, the appeal by the assessee was allowed without examining the merits of the additions. Case-Laws Income Tax Fri, 03 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776172