Non-Application of Mind and Wrong AY Render Sec 147 Reopening Void – ITAT Kolkata

Labh Combines Pvt. Ltd. Vs DCIT (ITAT Kolkata)

Reopening Quashed for Non-Application of Mind – Wrong AY Borrowed Satisfaction from Investigation Wing – Sec 147 Jurisdiction Invalid – ITAT Kolkata

ITAT Kolkata quashed reassessment holding that AO reopened case mechanically based on investigation wing information relating to wrong financial year, demonstrating complete non-application of mind. Tribunal observed that reasons recorded merely reproduced third-party report without establishing live nexus with escapement of income for relevant AY, amounting t

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