Paresh Babubhai Bahalani v. ITO (2024) 296 Taxman 324 /463 ITR 103 (Guj)(HC)

S. 147 : Reassessment-With in four years-Undisclosed investment-Not recording of independent satisfaction-Reassessment notice and order disposing the objection is quashed [S.69B, 148, Art. 226]

 

When the detailed reasons, such as the nature of the transaction, date of transactions, and name of the party with whom the transaction was entered into, were not provided-the reopening of an assessment was not justified. Unless the AO records his independent satisfaction in the reasons recorded based on information received and communicates the same to the assessee, the right of the assessee to file objections would remain an empty formality. (AY. 2017-18)