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The ITAT ruled that failure to issue a mandatory Section 143(2) notice and disregarding an e-verified return rendered the reassessment void. The addition of ₹50.50 lakh was deleted.
ITAT Delhi remanded the case to verify whether imports made using a firm’s PAN were recorded in the company’s books. CIT(A) deletion was quashed as factual examination was needed.
ITAT held that reopening of assessment based solely on investigation inputs without independent verification is invalid. The reassessment and 1% commission addition were deleted, reinforcing the requirement for AO’s own application of mind.
The Tribunal held that reassessment beyond four years is invalid when the AO fails to show how the assessee withheld material facts. The AO merely copied Investigation Wing inputs without independent reasoning. The entire reassessment was declared void for violating the proviso to Section 147.
ITAT ruled that reopening was bad in law as reasons cited property purchases, while additions related to cash credits—showing no live nexus. The case reaffirms that reassessment must be based on specific, relevant material.
ITAT confirmed Section 263 revision after finding that the AO wrongly allowed delayed PF/ESI contributions despite binding Supreme Court law. The reassessment was deemed erroneous and prejudicial to Revenue.
The Court held that Section 148 notices dated 31 March 2021 but issued after that date could not be treated as issued within the old limitation period. The ruling applies the amended reassessment framework and the Supreme Court’s directions in similar cases.
The Tribunal noted that the Assessing Officers communication did not consider the assessees objections but only reiterated the basis of reopening. As the objections were not disposed of through a separate speaking order, the reassessment lacked jurisdiction. The ruling underscores that non-compliance with GKN Driveshafts cannot be treated as a mere procedural lapse.
The Tribunal held that notices under section 153C issued without independent satisfaction by the AO are invalid, quashing the consequent assessments for AY 2018-19 to 2020-21.
The Tribunal held that reopening the assessment on the same grounds already examined in the original scrutiny amounted to an impermissible change of opinion. With no new material on record, the reassessment was found invalid. The ruling reinforces that the AO cannot revisit an earlier view in the guise of section 147 proceedings.
