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    <title>2026 (4) TMI 246 - ITAT DELHI</title>
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    <description>A reassessment challenge turned on the validity of a section 148 notice signed by the jurisdictional Assessing Officer rather than the Faceless Assessing Officer, and the objection on that ground was rejected because binding precedent had already upheld such notice. The reassessment was nevertheless quashed because the recorded reasons alleged escapement on facts unrelated to the assessee&#039;s return position, where the income had already been offered and the relevant gain was adjusted against brought-forward loss. The section 151 approval was found mechanical and showed no application of mind, and reliance on section 115BBE did not cure the defect because set-off was not then barred. The reassessment was held void ab initio.</description>
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      <title>2026 (4) TMI 246 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=789177</link>
      <description>A reassessment challenge turned on the validity of a section 148 notice signed by the jurisdictional Assessing Officer rather than the Faceless Assessing Officer, and the objection on that ground was rejected because binding precedent had already upheld such notice. The reassessment was nevertheless quashed because the recorded reasons alleged escapement on facts unrelated to the assessee&#039;s return position, where the income had already been offered and the relevant gain was adjusted against brought-forward loss. The section 151 approval was found mechanical and showed no application of mind, and reliance on section 115BBE did not cure the defect because set-off was not then barred. The reassessment was held void ab initio.</description>
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