https://www.taxtmi.com/caselaws?id=464273 ITAT (Del-AT) allowed the appeal, holding the reopening under s.147 barred by the first proviso as the AO failed to allege any non-disclosure of material facts by the assessee. The reasons for reopening were cursory and the s.151 approval was mechanical, rendering the exercise of jurisdiction vitiated. The assessment framed u/s.147 r.w. s.143(3) was quashed for lack of valid jurisdiction. en-us Thu, 02 Jun 2022 00:00:00 +0530 Wed, 15 Oct 2025 20:49:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464273 ITAT (Del-AT) allowed the appeal, holding the reopening under s.147 barred by the first proviso as the AO failed to allege any non-disclosure of material facts by the assessee. The reasons for reopening were cursory and the s.151 approval was mechanical, rendering the exercise of jurisdiction vitiated. The assessment framed u/s.147 r.w. s.143(3) was quashed for lack of valid jurisdiction. Case-Laws Income Tax Thu, 02 Jun 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464273