Reopening without Escapement

The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) quashed reassessment proceedings initiated under Section 147 of the Income-tax Act after holding that the alleged accommodation entries relied upon by the Assessing Officer were, in fact, sale proceeds received against disclosed business transactions. 

Since the receipts had already been accounted for in the books and offered to tax, the Tribunal found no basis for forming a belief that income had escaped assessment. The reassessment was consequently held to be void ab initio.