Reopening Quashed for Non-Application of Mind & Wrong Sanction

Advertisement RMP Holdings Private Limited Vs ITO (ITAT Delhi) ITAT Delhi quashed reassessment for AY 2012-13 as the AO wrongly recorded that assessment was being made for the first time, despite a completed scrutiny u/s 143(3). Reasons neither reflected true facts nor recorded failure of the assessee to disclose fully & truly material facts—making reopening beyond four years invalid. Approval was also found mechanical. Following its own order in assessee’s case for earlier year, the Tribunal held reopening u/s 147/148 void ab initio; additions u/s 68 became academic. For AY 2014-15...