#Section 147 ITA

ITAT Delhi sets aside reassessment notices issued under Sections 147/148 of the Income Tax Act, ruling that mere conjectural estimates from accommodation entry networks do not meet the threshold of 'tangible evidence'. The decision reinforces the principle that reassessment proceedings must be grounded in concrete facts, not assumptions, safeguarding taxpayers from arbitrary scrutiny.

ITAT Ahmedabad quashed a reassessment notice under Section 147/148 of the Income Tax Act, ruling that the Assessing Officer’s satisfaction must be based on independent application of mind and tangible evidence linking the assessee to escaped income. The Tribunal emphasized that borrowed satisfaction or conjectural reasoning violates natural justice and renders the reassessment void.