Wrong Approval u/s 151(ii) Vitiates Reassessment: ITAT Bangalore Quashes 147 Order & Entire Proceedings (AY 2016-17)

Pradip Kumar Roy Vs ITO (ITAT Bangalore) The Bangalore ‘C’ Bench of the Income Tax Appellate Tribunal, Bangalore Bench allowed the appeal of Shri Rahul Meka for AY 2016-17 and quashed the reassessment proceedings, holding that the sanction obtained for reopening was from an incorrect authority, thereby rendering the notice u/s 148 and consequent assessment void ab initio. The assessee, a non-resident, had originally declared income of ₹15,850, but the AO reopened the case and made additions including ₹47 lakh u/s 68 and ₹28.53 lakh LTCG with denial of exemption u/s 54F. The Tribunal ...