Taxpayer Wins: Section 147 Reassessment Invalidated Due to Incorrect Factual Basis in Original Income Determination

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....ITAT quashed reassessment proceedings initiated under Section 147 after finding the Assessing Officer's belief was predicated on incorrect factual understanding. Original assessment was already completed under Section 143(3) on 09/03/2001, determining total income at INR 105,85,36,899. Subsequent reassessment proceedings initiated on 25/03/2004 and assessment order dated 30/03/2006 were deemed unsustainable in law, as the foundational premise for reopening the assessment was factually erroneous. The tribunal held that the reassessment notice dated 28/02/2005 and subsequent proceedings did not meet statutory requirements, thereby rendering them invalid and liable to be quashed.....