https://www.taxtmi.com/caselaws?id=781523 ITAT Delhi - AT held that reopening under s.147 was invalid because the AO recorded reasons based solely on information from the DCIT without any independent inquiry or documentary evidence of escapement of income. The PCIT erred in confirming those reasons and the resulting addition, which evidenced non-application of mind. As the foundational facts for reopening were incorrect and the AO erred in law and fact, the reassessment proceedings were quashed and the assessee's appeal allowed. en-us Mon, 27 Oct 2025 00:00:00 +0530 Sat, 15 Nov 2025 09:54:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=781523 ITAT Delhi - AT held that reopening under s.147 was invalid because the AO recorded reasons based solely on information from the DCIT without any independent inquiry or documentary evidence of escapement of income. The PCIT erred in confirming those reasons and the resulting addition, which evidenced non-application of mind. As the foundational facts for reopening were incorrect and the AO erred in law and fact, the reassessment proceedings were quashed and the assessee's appeal allowed. Case-Laws Income Tax Mon, 27 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=781523