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Borrowed Satisfaction & Zero Independent Enquiry: ITAT Delhi Sets Aside Reassessment
Case Law Details
- Case Name
- Marigold Merchandise Private Limited Vs ACIT (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2012-13
- Courts
- All ITAT, ITAT Delhi
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Marigold Merchandise Private Limited Vs ACIT (ITAT Delhi)
Borrowed Satisfaction & Zero Independent Enquiry—ITAT Delhi Sets Aside Reassessment & Deletes 1% Commission Addition-No Tangible Material, No Application of Mind: ITAT Strikes Down 148 Notice Based Solely on Investigation Wing Inputs
Assessee had originally been assessed u/s 153B(1)(b) r.w.s. 143(3) on 29.03.2014. AO later reopened the case u/s 147 by issuing notice u/s 148 on 31.03.2019—well beyond four years. Tribunal noted that in such cases the proviso to Sec.147 mandates AO to clearly demonstrate Assess...
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