Taxpayer Wins: Section 147 Reassessment Invalidated Due to Incorrect Factual Basis in Original Income Determination

ITAT quashed reassessment proceedings initiated under Section 147 after finding the Assessing Officer's belief was predicated on incorrect factual understanding. Original assessment was already completed under Section 143(3) on 09/03/2001, determining total income at INR 105,85,36,899. Subsequent reassessment proceedings initiated on 25/03/2004 and assessment order dated 30/03/2006 were deemed unsustainable in law, as the foundational premise for reopening the assessment was factually erroneous. The tribunal held that the reassessment notice dated 28/02/2005 and subsequent proceedings did not meet statutory requirements, thereby rendering them invalid and liable to be quashed. .....

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