https://www.taxtmi.com/caselaws?id=782521 ITAT Delhi-AT quashed the reassessment initiated u/s 147/148 against the assessee. It held that the AO had reopened the assessment mechanically and solely on the basis of information from the Investigation Wing regarding alleged bogus transactions with a specified company, without conducting independent enquiry or forming his own reason to believe that income had escaped assessment. The reasons recorded were merely a reproduction of the investigation report and did not constitute tangible material. Further, the approval u/s 151 by PCIT, expressed in a routine satisfaction note, was found to be mechanical and without application of mind. Consequently, both the sanction u/s 151 and the notice u/s 148 were declared invalid, and the reassessment proceedings were set aside. en-us Mon, 24 Nov 2025 00:00:00 +0530 Mon, 01 Dec 2025 08:50:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782521 ITAT Delhi-AT quashed the reassessment initiated u/s 147/148 against the assessee. It held that the AO had reopened the assessment mechanically and solely on the basis of information from the Investigation Wing regarding alleged bogus transactions with a specified company, without conducting independent enquiry or forming his own reason to believe that income had escaped assessment. The reasons recorded were merely a reproduction of the investigation report and did not constitute tangible material. Further, the approval u/s 151 by PCIT, expressed in a routine satisfaction note, was found to be mechanical and without application of mind. Consequently, both the sanction u/s 151 and the notice u/s 148 were declared invalid, and the reassessment proceedings were set aside. Case-Laws Income Tax Mon, 24 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782521