Case Law Analysis
|Income Tax Appellate Tribunal
Section 147 Income Tax Act | Reassessment Invalid if AO Deviates from Proposed Reason: ITAT Delhi
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.