ITAT Delhi Quashes Reassessment as Wrong Explanation Invoked & Casual Approval

Bhageria Finance & Investment Private Limited Vs ITO (ITAT Delhi) AO wrongly invoked Explanation 2(b) instead of 2(c) to Section 147 despite completed assessment under 143(3); non‑application of mind – Assessment quashed In the case of assessee (AY 2012-13), the assessee challenged the reassessment proceedings initiated under Section 147/148 of the Income Tax Act. The core issue was that the Assessing Officer wrongly invoked Explanation 2(b) (applicable where no assessment has been made) despite the fact that a regular assessment under Section 143(3) had already been completed. The...