Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2023 (5) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2023 (5) TMI 1041 - ITAT DELHIReopening of assessment u/s 147 - unexplained investment - contradiction in reasons to believe - whether AO has tangible material in his possession for the purpose of initiating the reassessment proceedings in the case of appellant? - HELD THAT:- Reasons recorded and consequent assessment completed are full of contradictions giving wrong figures and wrong names in the case of assessee. It is also noted by ld. CIT (A) that during remand proceedings also, the AO was asked to reconcile the aforesaid figures of amounts and also the names but he failed to do so. CIT (A)’s finding that the AO has formed his belief for recording the reasons and reopening the assessment proceedings on the basis of the wrong premise is correct. CIT (A) has properly appreciated the matter and referred to case laws. His order does not need any interference on our part. Hence, we uphold the order of ld. CIT (A). As regards merits of the case, we note that reopening has been found invalid and grounds on merits are only academic interest - Appeal of the Revenue is dismissed.
|