Incorrect Assumption of Facts Renders Reopening Legally Untenable

Regalia Jewels Pvt. Ltd Vs DCIT/ACIT (ITAT Delhi) ITAT Delhi rules tax reassessment invalid under Section 147 as AO’s ‘reason to believe’ was based on an incorrect assumption of facts about purchases; ITAT Quashes Tax Reassessment Based on Flawed Factual Premise; Dehradun Bench Rules Incorrect Assumption Invalidates Reopening Jurisdiction Dehradun: The Income Tax Appellate Tribunal (ITAT), Delhi Bench (Dehradun), has set aside a reassessment order passed under Section 147 of the Income Tax Act, 1961, ruling that the Assessing Officer (AO) had invalidly assumed jurisdiction ...