ITAT Delhi Quashes Reassessment for Mechanical Section 148 Notice & Wrong Assumption of Non-Filing

Om Kar Singh Vs ITO (ITAT Delhi) ITAT Delhi quashes reassessment—AO wrongly assumed no return filed; mechanical 148 notice held invalid Delhi annulled the reassessment, holding that the notice u/s 148 was issued without application of mind on a wrong premise that Assessee had not filed any return. AO reopened the case based on NMS data showing large cash deposits of ₹15.21 crore, assuming no ITR was filed. In reality, Assessee had filed return on 15-09-2017, a fact even acknowledged later in the assessment order. ITAT found that reopening was entirely mechanical & factually incorrect, ...