https://www.taxtmi.com/caselaws?id=781098 ITAT Delhi (AT) held that reassessment proceedings under section 147 were void ab initio because the AO relied solely on a non-filers list without recording specific reasons or tangible material showing escapement of income. The assessee, a foreign company and FPI, earned only interest subject to TDS under section 194LD, and had furnished TRC, FPI status, withholding certificates and other documentary proof showing foreign residency and POEM/PE not applicable. Absent proper reasons recorded, AO lacked jurisdiction to reopen; appeal allowed and reassessment quashed. en-us Thu, 06 Nov 2025 00:00:00 +0530 Tue, 11 Nov 2025 08:20:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=781098 ITAT Delhi (AT) held that reassessment proceedings under section 147 were void ab initio because the AO relied solely on a non-filers list without recording specific reasons or tangible material showing escapement of income. The assessee, a foreign company and FPI, earned only interest subject to TDS under section 194LD, and had furnished TRC, FPI status, withholding certificates and other documentary proof showing foreign residency and POEM/PE not applicable. Absent proper reasons recorded, AO lacked jurisdiction to reopen; appeal allowed and reassessment quashed. Case-Laws Income Tax Thu, 06 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=781098