https://www.taxtmi.com/caselaws?id=781676 ITAT, Ahmedabad (AT) held that reassessments under s.147 for A.Y. 2014-15, 2015-16, 2017-18 and 2018-19 were invalid for want of independent, recorded belief by the AO that income had escaped assessment. The AO failed to identify the specific income escaping assessment or specify the alleged disproportionate asset, and merely relied on ACB information without applying his own mind. Consequently the s.147 assessments were quashed and orders issued by the PCIT under s.263 in respect of those years were held unsustainable. en-us Fri, 17 Oct 2025 00:00:00 +0530 Wed, 19 Nov 2025 08:52:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=781676 ITAT, Ahmedabad (AT) held that reassessments under s.147 for A.Y. 2014-15, 2015-16, 2017-18 and 2018-19 were invalid for want of independent, recorded belief by the AO that income had escaped assessment. The AO failed to identify the specific income escaping assessment or specify the alleged disproportionate asset, and merely relied on ACB information without applying his own mind. Consequently the s.147 assessments were quashed and orders issued by the PCIT under s.263 in respect of those years were held unsustainable. Case-Laws Income Tax Fri, 17 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=781676