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    <title>2026 (6) TMI 1115 - ITAT DELHI</title>
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    <description>Reassessment was invalid where the Assessing Officer invoked Explanation 2(b) to section 147 on the mistaken assumption that the return had only been processed under section 143(1), although the assessee had already been scrutinised under section 143(3). The recorded reasons were based on an incorrect factual and legal premise and showed non-application of mind. On that basis, the reassessment machinery was held to be vitiated, and the reassessment proceedings were quashed in favour of the assessee.</description>
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      <description>Reassessment was invalid where the Assessing Officer invoked Explanation 2(b) to section 147 on the mistaken assumption that the return had only been processed under section 143(1), although the assessee had already been scrutinised under section 143(3). The recorded reasons were based on an incorrect factual and legal premise and showed non-application of mind. On that basis, the reassessment machinery was held to be vitiated, and the reassessment proceedings were quashed in favour of the assessee.</description>
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