#Section 147 Income Tax Act

The ITAT Delhi set aside a Rs. 35 lakh addition for unexplained cash deposits during demonetization because the reassessment under Section 147 lacked mandatory reasons and failed to secure prior approval under Section 151. Only Rs. 3 lakh was upheld after scrutiny, reinforcing that procedural compliance is non-negotiable in reassessments - a critical safeguard for taxpayers facing post-demonetization scrutiny.

The ITAT Agra has ruled that reassessment under Section 147 is void if the Assessing Officer relies on cash transaction data without verifying the assessee’s explanation or making any actual addition to income. This establishes that mere suspicion or unverified data cannot sustain jurisdictional belief - a critical safeguard for small traders and cash-based businesses facing arbitrary reassessments.

The ITAT Delhi has held that a reassessment under Section 147 is legally invalid when the Assessing Officer departs from the reason initially proposed for reopening, establishing that procedural consistency is mandatory-not optional. This ruling binds tax authorities to their stated grounds, protecting taxpayers from arbitrary reassessments based on shifting justifications.

ITAT Kolkata sets aside reassessment proceedings initiated under Section 147 where the Assessing Officer relied exclusively on an investigation wing report without independent scrutiny. The ruling reinforces that procedural fairness mandates personal satisfaction of the AO, not borrowed satisfaction, to uphold reassessment validity.

ITAT Mumbai quashed reassessment proceedings under Section 147 of the Income Tax Act initiated after four years, ruling that the absence of new tangible material or failure to disclose material facts invalidates such actions. The decision reinforces statutory safeguards against arbitrary reopening of assessments, impacting taxpayers facing similar reassessment notices.

ITAT Delhi rules that reassessment proceedings under Section 147 of the Income Tax Act are invalid if the assessing officer makes additions on grounds not specified in the original reopening notice. The tribunal emphasized that the scope of reassessment cannot expand beyond the reasons recorded for reopening, reinforcing procedural safeguards for taxpayers.

ITAT condones delay and restores assessment proceedings to ensure fair hearing, emphasizing that technical defaults cannot override substantive justice in tax appeals.