Reassessment Quashed for Wrong Factual Assumption; Notice u/s 148 Held Void ab initio

Seema Puri Vs ITO (ITAT Delhi) The Delhi Bench (SMC) of the ITAT allowed the appeal of Seema Puri for AY 2011-12 and quashed the reassessment proceedings initiated under sections 147/148 as being bad in law. The Tribunal found that the very foundation of the reopening was factually incorrect. One of the core reasons recorded by the Assessing Officer was that the assessee had not filed her return of income, whereas, in reality, the assessee had duly filed her return under section 139(1) on 31.07.2011, a fact also acknowledged by the AO in the assessment order. Reopening an assessment on such a ...