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    <title>2025 (11) TMI 1764 - ITAT DELHI</title>
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    <description>ITAT Delhi quashed the reassessment initiated under s.147/148 on the ground that the notice was issued with an incorrect PAN and in a mechanical manner without proper application of mind. The AO relied on third-party information alleging accommodation entries of INR 3.50 crores but failed to conduct any enquiry or verify existing assessment records, which already contained confirmations for loans received and an earlier s.143(3) assessment. Further, approval under s.151(2) by the Pr. CIT was granted mechanically. The notice under s.148 and all consequential reassessment proceedings were held invalid and the assessee&#039;s appeal was allowed.</description>
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      <title>2025 (11) TMI 1764 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=782296</link>
      <description>ITAT Delhi quashed the reassessment initiated under s.147/148 on the ground that the notice was issued with an incorrect PAN and in a mechanical manner without proper application of mind. The AO relied on third-party information alleging accommodation entries of INR 3.50 crores but failed to conduct any enquiry or verify existing assessment records, which already contained confirmations for loans received and an earlier s.143(3) assessment. Further, approval under s.151(2) by the Pr. CIT was granted mechanically. The notice under s.148 and all consequential reassessment proceedings were held invalid and the assessee&#039;s appeal was allowed.</description>
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