https://www.taxtmi.com/caselaws?id=776774 ITAT held the reopening under s.147 invalid and quashed reassessment; appeal allowed. The AO's "reasons to believe" were vague and showed non-application of mind, lacking specific observations required to assume jurisdiction. The AO failed to verify that a return had been filed and did not consider that the payment was recorded as loans and advances in the relevant year, with the actual immovable property purchase occurring in the subsequent year (sale deed dated 29.04.2017) - facts supported on record and before CIT(A). These omissions rendered the reopening bad in law. en-us Mon, 11 Aug 2025 00:00:00 +0530 Tue, 19 Aug 2025 08:38:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776774 ITAT held the reopening under s.147 invalid and quashed reassessment; appeal allowed. The AO's "reasons to believe" were vague and showed non-application of mind, lacking specific observations required to assume jurisdiction. The AO failed to verify that a return had been filed and did not consider that the payment was recorded as loans and advances in the relevant year, with the actual immovable property purchase occurring in the subsequent year (sale deed dated 29.04.2017) - facts supported on record and before CIT(A). These omissions rendered the reopening bad in law. Case-Laws Income Tax Mon, 11 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776774