https://www.taxtmi.com/caselaws?id=777721 ITAT held that reopening of assessment u/s 147 was invalid where AO's approval u/s 151 and reasons for issuing notice u/s 149 were mechanical and unsupported by material. Survey on 27/09/2018 occurred beyond four years from end of AY 2012-13, and AO's belief that income was understated by over Rs.1,00,000 lacked nexus or tangible evidence (no prima facie material showing expenditure on showroom exceeding Rs.1,00,000). Consequently AO lacked jurisdiction to reassess; notice u/s 148 was set aside and the assessee's appeal was allowed. en-us Mon, 13 Jan 2025 00:00:00 +0530 Tue, 02 Sep 2025 10:44:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=777721 ITAT held that reopening of assessment u/s 147 was invalid where AO's approval u/s 151 and reasons for issuing notice u/s 149 were mechanical and unsupported by material. Survey on 27/09/2018 occurred beyond four years from end of AY 2012-13, and AO's belief that income was understated by over Rs.1,00,000 lacked nexus or tangible evidence (no prima facie material showing expenditure on showroom exceeding Rs.1,00,000). Consequently AO lacked jurisdiction to reassess; notice u/s 148 was set aside and the assessee's appeal was allowed. Case-Laws Income Tax Mon, 13 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=777721