No Property, No Proof, No Mind – ITAT Slams “Blind” 147 Reopening & Upholds Quash

ITO Vs Bhavneet Kaur Walia (ITAT Chandigarh)

Mechanical Reopening Without Any Evidence – ITAT Upholds Quashing of Entire 147 Proceedings

AO reopened the assessment u/s 147 purely on the basis of an Investigation Wing alert, alleging that Assessee had made undisclosed investment of ₹2,86,42,500 in an immovable property.

Throughout the reassessment proceedings, Assessee repeatedly requested basic details such as:

• Which property?
• Address & description?
• Name of selle

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