Section 148 Reopening Invalid Without Independent Application of Mind: ITAT Delhi

Advertisement V & S International Pvt. Ltd. Vs DCIT (ITAT Delhi) The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) allowed the assessee’s appeal for Assessment Year 2005-06, quashing the notice issued under Section 148 and the consequent reassessment order passed under Sections 143(3)/147. The Tribunal held that the reassessment proceedings were invalid as the Assessing Officer (AO) had reopened the assessment solely on the basis of information received from the Investigation Wing without independently applying his mind or establishing a live link between the information...