No reassessment unless there was new tangible evidence found against assessee

Samtel India Limited Vs ACIT (ITAT Delhi)

Conclusion: Since no new material or facts had come to light and the AO had already applied his mind during the original assessment, the reassessment proceedings were invalid in law  accordingly, Section 148 notice was quashed.

Held: In the instant case, during the course of assessment proceedings, assessee had objected the reopening and filed a details objection of the assessment order. Such objections were disposed off by AO in the assessment order itself wherein AO observed that certain factual

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