AO’s Reopening Under Section 147 Set Aside Over Incorrect Filing Claim

Harish Kumar Singh Vs ITO (ITAT Delhi) Reopening quashed: AO assumed non-filing despite return on record; reasons held factually incorrect; appeal partly allowed In this appeal by Harish Kumar Singh for AY 2012-13, Tribunal examined the validity of assessment framed u/s 147 after reopening based on AIR information of cash deposits of ₹51.07 lakh. AO recorded reasons alleging that assessee was a “non-filer” & had not filed any return for the relevant year, obtained approval, issued notice u/s 148 & completed reassessment. At the outset, Tribunal addressed a procedural objection re...