ITAT quashes reassessment order as notice was issued on incorrect facts without application of mind

Bhavmeet Singh Bhatia Vs ACIT (ITAT Delhi) AO noted that the assessee has not filed the return of income for AY 2011-12 whereas the copy of the return of income available in assessee’s paper book clearly reveals that the assessee did file the return of income for AY 2011-12. It is also clearly discernible that in the proforma for obtaining approval u/s 151 of the Act, in column 8(a), the AO noted that the assessee has not filed any return of income. Therefore, I safely presume that the AO has proceeded to initiate reassessment proceedings u/s 147 of the Act and issued notice u/s 148 on incor...