https://www.taxtmi.com/caselaws?id=782867 ITAT Delhi (AT) allowed the assessee's appeal, holding the reassessment proceedings under s.148 invalid. The AO reopened assessment for A.Y. 2012-13 on the basis of reasons pertaining to A.Y. 2011-12 and on incorrect factual assumptions regarding purchase of immovable property. The Tribunal found that the sale deed clearly showed three co-purchasers and that possession was handed over to all buyers, whereas the AO treated the assessee as sole purchaser and omitted these material facts in the recorded reasons. Further, the sanction for reopening was granted mechanically without proper application of mind. Consequently, the reassessment was held void ab initio and the order of CIT(A) dismissing the appeal was set aside. en-us Wed, 19 Nov 2025 00:00:00 +0530 Fri, 05 Dec 2025 08:12:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782867 ITAT Delhi (AT) allowed the assessee's appeal, holding the reassessment proceedings under s.148 invalid. The AO reopened assessment for A.Y. 2012-13 on the basis of reasons pertaining to A.Y. 2011-12 and on incorrect factual assumptions regarding purchase of immovable property. The Tribunal found that the sale deed clearly showed three co-purchasers and that possession was handed over to all buyers, whereas the AO treated the assessee as sole purchaser and omitted these material facts in the recorded reasons. Further, the sanction for reopening was granted mechanically without proper application of mind. Consequently, the reassessment was held void ab initio and the order of CIT(A) dismissing the appeal was set aside. Case-Laws Income Tax Wed, 19 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782867