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Approval for One Issue, Reopening for Another Is Legally Fatal
Case Law Details
- Case Name
- Kanubhai Ramdas Patel Vs ITO (ITAT Ahmedabad)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2012-13
- Courts
- ITAT Ahmedabad
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Kanubhai Ramdas Patel Vs ITO (ITAT Ahmedabad)
Approval Says “Commodity Trading”, Reasons Say “LTCG”-Defective 151 Approval Dooms Penny-Stock Reopening-Unsigned / Mismatched Sanction u/s 151 Is Fatal
Ahmedabad ITAT ‘SMC’ Bench in Kanubhai Ramdas Patel vs ITO (ITA No.1207/Ahd/2024, AY 2012-13, order dated 24-12-2025) allowed the assessee’s appeal and quashed the entire reassessment u/s 147 as void ab initio, holding that the mandatory approval u/s 151 suffered from fatal defects and total non-application of mind
Assessee, a proprietor engaged in agricultural tradi...
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