Reopening Quashed Due to Total Non-Application of Mind

Optus Developers Pvt. Ltd. Vs ACIT (ITAT Delhi) Reopening Quashed for Total Non-Application of Mind – Search Dates, Persons & Reasons Keep Changing Delhi ITAT quashed reassessment proceedings holding that notices u/s 148 were issued in a mechanical & casual manner, suffering from patent non-application of mind. For AY 2016-17, Tribunal noted that Assessee was undisputedly a non-searched person, yet AO issued notice u/s 148 stating that a search u/s 132 was initiated in Assessee’s case. Assessment order thereafter referred to entirely different search actions on different persons &a...