Reassessment Quashed for Relying on Wrong Person’s Transactions

Darshan Lal Makhija Vs ITO (ITAT Delhi) The appeal for Assessment Year 2017–18 arose from an order passed by the CIT(A)/NFAC, Delhi, in reassessment proceedings under sections 147 read with 144 of the Income-tax Act, 1961. The Tribunal first condoned a delay of 231 days in filing the appeal, holding that it was in the larger interest of justice. During the hearing, the assessee raised a primary legal objection challenging the validity of the reopening itself. It was pointed out that the notice issued under section 148A(b) by the Assessing Officer referred to information concerning transactio...