Case Law Analysis
|Income Tax Appellate Tribunal
Section 147/148 ITA | Reassessment Without Tangible Evidence Violates Natural Justice : ITAT Delhi Quashes Conjecture-Based Notices
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.