AO Cannot Reopen Assessment Based Only on Investigation Inputs

Belong Tracom Private Limited Vs ITO (ITAT Guwahati) Borrowed Satisfaction Fatal: Guwahati ITAT Quashes Reopening Based Solely on Investigation Wing Input The Guwahati Bench of the ITAT allowed the appeal of Belong Tracom Pvt. Ltd. vs. ITO, Ward 2(1), Dibrugarh, ITA No. 254/GTY/2019, AY 2011-12, vide order dated 18.12.2025, and quashed the reopening u/s 147 and notice u/s 148 as being bad in law The Assessee had originally filed its return declaring a nominal loss, which was processed u/s 143(1). Subsequently, the AO reopened the assessment based on information received from the Investigation ...