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2016 (8) TMI 1547 - AT - Income TaxReopening of assessment u/s 147 - application v/s non application of mind by AO - Reopening on basis of information allegedly received by him from the Directorate of Income Tax (Investigation) - HELD THAT:- AO has not applied his mind so as to come to an independent conclusion that he has reason to believe that income has escaped during the year. In our view the reasons are vague and are not based on any tangible material as well as are not acceptable in the eyes of law. The AO has mechanically issued notice u/s. 148 of the Act, on the basis of information allegedly received by him from the Directorate of Income Tax (Investigation), New Delhi As issue involved in the present appeal and is squarely covered by the aforesaid decisions of the Hon’ble High Court of Delhi in the case of G&G Pharma [2015 (10) TMI 754 - DELHI HIGH COURT] & Signatures Hotels (P) Ltd. [2011 (7) TMI 361 - DELHI HIGH COURT] Hence, we decide the legal issue in dispute in favor of the Assessee and against the Revenue and accordingly quash the reassessment proceedings and allow the ground no. 1 & 2 raised by the Assessee.
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