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    <title>2024 (5) TMI 1707 - ITAT DELHI</title>
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    <description>Reassessment beyond four years was treated as invalid where the recorded reasons merely repeated Investigation Wing material and showed no independent application of mind by the Assessing Officer. The reopening also failed because the precondition of a full and true disclosure failure was not established on the original assessment record, which had already been completed under section 143(3). The reasons proceeded on mistaken factual assumptions, including an incorrect link to another entity and an unsupported claim that relevant documents had not been furnished earlier. Denial of cross-examination further reinforced the defect, and the reassessment notice, proceedings and resulting addition were set aside as bad in law.</description>
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      <link>https://www.taxtmi.com/caselaws?id=469672</link>
      <description>Reassessment beyond four years was treated as invalid where the recorded reasons merely repeated Investigation Wing material and showed no independent application of mind by the Assessing Officer. The reopening also failed because the precondition of a full and true disclosure failure was not established on the original assessment record, which had already been completed under section 143(3). The reasons proceeded on mistaken factual assumptions, including an incorrect link to another entity and an unsupported claim that relevant documents had not been furnished earlier. Denial of cross-examination further reinforced the defect, and the reassessment notice, proceedings and resulting addition were set aside as bad in law.</description>
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