https://www.taxtmi.com/caselaws?id=782752 The ITAT Delhi set aside the reassessment initiated under s.147 for AY 2015-16, holding the assumption of jurisdiction to be invalid and the proceedings void ab initio. It found that the AO recorded reasons on an incorrect factual premise, failing to clearly identify whether the alleged accommodation entries constituted bogus expenditure or unexplained cash credits under s.68. The AO also issued notice and completed reassessment under the old regime despite the applicability of the amended s.148A framework, rendering the process illegal. Further, sanction under s.151 was held to be mechanical and without proper application of mind. The assessee's appeal was allowed in full. en-us Fri, 28 Nov 2025 00:00:00 +0530 Wed, 03 Dec 2025 08:57:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782752 The ITAT Delhi set aside the reassessment initiated under s.147 for AY 2015-16, holding the assumption of jurisdiction to be invalid and the proceedings void ab initio. It found that the AO recorded reasons on an incorrect factual premise, failing to clearly identify whether the alleged accommodation entries constituted bogus expenditure or unexplained cash credits under s.68. The AO also issued notice and completed reassessment under the old regime despite the applicability of the amended s.148A framework, rendering the process illegal. Further, sanction under s.151 was held to be mechanical and without proper application of mind. The assessee's appeal was allowed in full. Case-Laws Income Tax Fri, 28 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782752